Kami Iron Ore Project.

KAMI IRON ORE MINE &RAIL INFRASTRUCTURE,LabradorKami Iron Ore ProjectEnvironmental Impact StatementPLAIN LANGUAGE SUMMARY September 2012

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryKami Iron Ore Project.a summary of theenvironmental impact statementii

ForewordThis document is intended to be a non-technical summary ofthe Environmental Impact Statement (EIS) for the Kami Iron OreProject proposed by Alderon Iron Ore Corp located in westernLabrador. The purpose of this document is to provide an overviewof key findings of the EIS with respect to potential Project-relatedenvironmental effects as well as commitments to managingthose effects to acceptable levels over the life of the Project. Thisdocument is intended to support Aboriginal engagement and publicconsultation and is available in English and French. Readers areencouraged to review the full EIS document for additional details onthe assessment.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryPrinted on EarthChoice® (Rainforest Alliance Certified and FSC Certified) Paperiii

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summaryiv

Table of Contents1.0 INTRODUCTION.................................................................................................................................................. 11.1 Project Overview....................................................................................................................................... 11.2 Environmental Assessment Process.......................................................................................................... 31.2.1 Purpose of the EIS....................................................................................................................... 31.2.2 Federal Requirements................................................................................................................. 31.2.3 Provincial Requirements............................................................................................................. 41.2.4 Cooperative EA Process.............................................................................................................. 42.0 PROJECT DESCRIPTION...................................................................................................................................... 52.1 Purpose of and Need for the Project........................................................................................................ 52.2 Project Description................................................................................................................................... 52.2.1 Location...................................................................................................................................... 52.2.2 Components............................................................................................................................... 52.2.3 Activities..................................................................................................................................... 92.2.4 Schedule..................................................................................................................................... 92.2.5 Labour Force Requirements...................................................................................................... 103.0 SCOPE OF THE ASSESSMENT........................................................................................................................... 113.1 Scope of the Project................................................................................................................................ 113.2 Factors to be Considered........................................................................................................................ 113.3 Scope of the Factors................................................................................................................................ 113.3.1 Identification of VECs................................................................................................................ 123.3.2 Spatial and Temporal Boundaries............................................................................................. 134.0 PROJECT ALTERNATIVES.................................................................................................................................. 144.1 Alternatives to the Project...................................................................................................................... 144.2 Alternative Means of Carrying out the Project.......................................................................................145.0 CONSULTATION................................................................................................................................................. 175.1 Public and Aboriginal Consultation and Engagement Activities undertaken for the EA.........................176.0 EXISTING ENVIRONMENT................................................................................................................................ 257.0 ENVIRONMENTAL EFFECTS ASSESSMENT...................................................................................................... 287.1 Method and Approach............................................................................................................................ 287.2 Valued Ecosystem Components.............................................................................................................. 317.2.1 Atmospheric Environment........................................................................................................ 317.2.2 Landforms, Soils, Snow and Ice................................................................................................ 347.2.3 Water Resources....................................................................................................................... 377.2.4 Wetlands................................................................................................................................... 407.2.5 Freshwater Fish, Fish Habitat and Fisheries.............................................................................. 427.2.6 Birds, Other Wildlife and Their Habitats and Protected Areas................................................. 457.2.7 Species at Risk and Species of Conservation Concern.............................................................. 497.2.8 Historic and Cultural Resources................................................................................................ 527.2.9 Current Use of Lands and Resources for Traditional Purposes by Aboriginal Persons..............547.2.10 Other Current Use of Lands and Resources.............................................................................. 587.2.11 Community Services and Infrastructure................................................................................... 617.2.12 Health and Community Health................................................................................................. 647.2.13 Economy, Employment and Business....................................................................................... 667.3 Effects of the Environment on the Project.............................................................................................. 697.3.1 Method and Approach.............................................................................................................. 697.3.2 Issues........................................................................................................................................ 697.3.3 Potential Environmental Effects................................................................................................ 697.3.4 Mitigation Measures................................................................................................................. 707.3.5 Residual Environmental Effects................................................................................................. 70Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summaryv

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary7.4 Effects of Possible Accidents or Malfunctions.........................................................................................707.4.1 Method and Approach.............................................................................................................. 707.4.2 Issues........................................................................................................................................ 707.4.3 Potential Environmental Effects................................................................................................ 717.4.4 Mitigation Measures................................................................................................................. 717.4.5 Residual Effects......................................................................................................................... 727.5 Effects on Capacity of Renewable Resources..........................................................................................727.6 Cumulative Environmental Effects.......................................................................................................... 727.6.1 Approach.................................................................................................................................. 727.6.2 Scoping..................................................................................................................................... 727.6.3 Issues........................................................................................................................................ 737.6.4 Potential Cumulative Effects..................................................................................................... 747.6.5 Mitigation Measures................................................................................................................. 757.6.6 Residual Effects......................................................................................................................... 758.0 FOLLOW-UP PROGRAM................................................................................................................................... 769.0 BENEFITS OF THE EA TO CANADIANS............................................................................................................. 7810.0 OVERALL CONCLUSIONS OF THE PROPONENT.............................................................................................. 7911.0 REFERENCES..................................................................................................................................................... 80APPENDIX A:VEC Summary Tables and Residual Effects Summary Matrices.................................................................................... 81APPENDIX B:Complete Record of all Comments Identified During Consultation and Engagement Activities with Responses......113vi

1.0 INTRODUCTIONAlderon Iron Ore Corp. (Alderon) is proposing to develop and operate an iron oremine on the Kamistiatusset (Kami) Property in western Labrador, which will have anominal capacity of 16 million metric tonnes of iron ore concentrate each year thatwill be transported by existing rail lines to the Pointe-Noire Terminal at the Port ofSept-Îles, Québec.Alderon is committed to taking a responsible approach to social, economicand environmental performance that is consistent with the priorities of ourstakeholders. Alderon’s goal is to build and maintain positive and long termrelationships with stakeholders of the proposed Kami Project.Alderon is committed to building relationships, based on mutual trust and respectand collaborating with Aboriginal groups that may be affected by the Project andthat have asserted or established Aboriginal rights, Aboriginal title or treaty rightsor whose traditional land and resource use activities in the Project area may beaffected by the Kami Project.This document describes the environmental effects of the proposed Kami mineand associated components located in western Labrador. A separate summarydocument has been prepared to describe Alderon’s proposed facilities in Québec.1.1 Project OverviewAlderon is proposing to develop an iron ore mine on the Kamistiatusset (Kami)Property located in western Labrador. The mine property is located south of thetowns of Wabush and Labrador City in Newfoundland and Labrador and eastof Fermont, Québec. The Kami Iron Ore Mine and Rail is located entirely withinLabrador. The Project includes construction, operation, and eventual closure andreclamation of an open pit, waste rock disposal areas, processing infrastructure,a tailings management facility and effluent treatment infrastructure, supportinginfrastructure and a rail transportationAlderon’s goal is to build andmaintain positive and long termrelationships with stakeholdersof the proposed Kami Project.component. Iron ore concentrate willbe transported by existing rail to thePointe-Noire Terminal at the Port ofSept-Îles. Project components withinthe Port of Sept-Îles are addressed in aseparate EIS and associated summarydocument.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary1

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryFigure: Kami Iron Ore Project General Location±U n g a v a B a y!Schefferville!Nain!Natuashish!Hopedale!PostvilleKamiMine SiteFermontLabrador City^_A T L A N T I CO C E A NWabushLicensesTshiuetinRailwayLabrador CityFermont!^_!KamiMine SiteWabushSmallwood Reservoir!Churchill Falls!!!SheshatshiuRigoletHappy Valley-Goose Bay!Cartwright!!ForteauCharlottetownQuebec North Shoreand Labrador Railway!^_Sept ÎlesTerminal SiteG u l f o f S t . L a w r e n c eFIGURE ID : ALD_ST_668b0 50 100Kilometres2

1.2 Environmental Assessment Process1.2.1 Purpose of the EISThe submission of the Environmental Impact Statement (EIS) is an importantstep in the environmental assessment review process. The EIS is a careful anddetailed consideration of howthe Project could affect theresidents, communities, and naturalenvironment surrounding the KamiProject site. The EIS addressesthe issues raised by regulators,the public and Aboriginal throughAlderon’s public consultationprocess. The EIS will be reviewed bythe EA Committee, including subjectarea experts from governmentdepartments and regulatoryagencies, and is available for publicreview. Review comments of the EACommittee and the public will beconsidered when a determinationof the environmental implicationsof the Project is made by the federaland provincial governments.The EIS consists of a Plain LanguageSummary, an Executive Summary,Volume 1 (Kami Iron Ore Mine andRail Infrastructure Project) andVolume 2 (Kami Concentrate Storageand Load-out Facility).1.2.2 FederalRequirementsAn environmentalassessment is a decisionmakingtool used topromote sustainabledevelopment byevaluating the potentialenvironmentaleffects of majordevelopments beforethey are constructed.This process involvesvarious governmentagencies as well aspublic, stakeholder andAboriginal consultationand engagement.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryFederal approvals will berequired from:• Fisheries and Oceans Canada (DFO) (Fisheries Act);• Transport Canada (Navigable Waters Protection Act);• Natural Resources Canada (Explosives Act); and• Canadian Transportation Agency (Canada Transportation Act).Under CEAA, a “comprehensive study” level of assessment will be required sincethe Kami mine will have an “iron ore capacity of 3,000 t/d or more”.3

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary1.2.3 Provincial RequirementsThe mine site is located entirely within Labrador and any mining of a mineraldefined in the Mineral Act in Newfoundland and Labrador is subject toenvironmental assessment registration under the province’s EnvironmentalProtection Act and Environmental Assessment Regulations.1.2.4 Cooperative EA ProcessThis Project will require approvals from provincial and federal governments,including environmental assessment approval under the Newfoundland andLabrador Environmental Protection Act and federal Canadian EnvironmentalAssessment Act (CEAA). Both governments are working together to use oneenvironmental assessment to satisfy their respective regulatory requirements.An environmental assessment is a decision-making tool used to promotesustainable development by evaluating the potential environmental effects ofmajor developments before they are constructed. This process involves variousgovernment agencies as well as public, stakeholder and Aboriginal consultationand engagement.The mining and mineral processingindustry is an important part ofthe Newfoundland and Labradoreconomy, and one which hasbeen identified as having greatpotential for future growth.4

2.0 PROJECT DESCRIPTION2.1 Purpose of and Need for the ProjectThe purpose of the Project is to develop the iron ore deposits within the KamiMine Property in Labrador to produce iron ore concentrate for sale to internationalmarkets. There is currently a very high level of demand for iron ore and steelworldwide, which is creating and maintaining relatively strong markets and goodprices for iron and steel.The mining and mineral processing industry is an important part of theNewfoundland and Labrador economy, and one which has been identified ashaving great potential for future growth. The future growth of the province’smining industry has also been identified as a key priority area of focus.This Project is an important element of this future strategic direction, and willcontribute strongly to the on-going capability and future growth of the province’smining industry. Additionally, the Project will have significant economic benefitsduring the construction and operation by creating employment opportunities aswell as opportunities for businesses that supply goods and services.2.2 Project Description2.2.1 LocationKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryThe proposed Kami mine site is located wholly within Labrador approximately 6km south from the Wabush Mines mining lease and in the vicinity of the towns ofWabush, Labrador City and Fermont.2.2.2 ComponentsThe Project will include the construction, operation and eventual closure andreclamation of the following key elements:• Open Pit Mine (Rose Pit);• Site Buildings;• Waste Rock Disposal Areas (Rose North and Rose South Disposal Areas);• Tailings Management Facility;• Effluent Treatment Infrastructure;• Access Roads;• Power / Transmission Lines;• Rail Infrastructure;• Other Supporting Infrastructure and Equipment.5

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryOpen Pit MineThe proposed Project will include an open pit mine (Rose Pit), which will be locatedjust south of Pike Lake, and approximately 8 km south of the communities ofWabush and Labrador City in western Labrador (as shown on Project Componentsmap). The surface area of the pit footprint will be approximately 280 ha, with anoverall perimeter of 8.6 km. The approximate pit depth will be 450 m.Mineral Processing Infrastructure and Site BuildingsThe proposed Project components at the mine site in Labrador will include miningand processing facilities, and various other site and supporting infrastructure,which will be located in two adjacent complexes at the mine site (as shownon Project Components map). The ore will be processed using grinding andmagnetic separation. To meet the nominal production of 16 million tonnes of ironconcentrate per year, a total of 42.4 million tonnes annually of crushed ore must befed to the grinding circuit.Key processing components and facilities will include:• Primary Crushers (above ground and underground);• Crushed Ore Stockpile;• Process Plant;• Concentrator Service Buildings.Project ComponentsCLM RailwayLabrador CityLittleWabush LakeWabush LakeTrans-Labrador HighwayQNS&L RailwayWabush Mines±Walsh RiverWabush MinesWabushDuley LakeProvincial ParkReserveLongLakeProposedPowerline(Nalcor)ProposedAccess RoadWahnahnish LakeRose NorthWaste RockDisposal AreaFacility BuildingsEffluent PipelinePolishingPondProposed RailwayRiordan LakeRose PitConveyorTailingsManagementFacilityLac DeviaultRose SouthWaste RockDisposal AreaWaldorfFermontRiverFIGURE ID: ALD_ST_669LABRADORQUÉBEC0 1 2Ki ometres6lLac CarheilCLIENT:CLIENT

Waste Rock Disposal AreasThe development of the open pit is expected to generate approximately 1,232million tonnes (Mt) of waste over the life of the mine. A total of approximately 660million cubic meters of waste storage capacity will be required on the site.To store the waste rock and overburden produced by the development of theKami deposit, conventional surface disposal areas are proposed near the RosePit, which are referred to as the Rose North and Rose South Waste Rock DisposalAreas. The Rose North Disposal Area will be located immediately to the northwestof the Rose Pit, and covers an area of approximately 136 ha (as shown on ProjectComponents map). The Rose South Disposal Area is located to the south of theaccess road and conveyor that connects the mine and crusher with the processingfacility, and is situated between Mills Lake and the Waldorf River, covering an areaof approximately 595 ha.Tailings Management FacilityTailings are the waste materials that are left over after the process of separatingthe valuable minerals from the unusable and uneconomic rock components.Tailings are different than overburden or waste rock which are the materialsoverlying an ore or mineral body that are displaced during mining without beingprocessed.The tailings will be dewatered at the processing plant using dewatering cyclonesfor dewatering coarse tailings and thickeners for dewatering dry tailings. Tailingsdewatering at the processing plant reduces pumping requirements and improveswater management by keeping water within the concentrator process water circuit.These tailings will be disposed of at a proposed Tailings Management Facilitylocated in the south-eastern portion of the Project area (as shown on ProjectComponents map). Excess water in the Tailings Management Facility will be sentto a polishing pond. Water in the polishing pond will be treated to meet dischargecriteria, set by the federal Metal Mining Effluent Regulations and provincialEnvironmental Control Water and Sewage Regulations, and to reduce potential forred water prior to being discharged into Long Lake. “Red water” is the term usedfor water which contains fine particles of iron oxide / hydroxide.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryThe proposed location of the Tailings Management Facility was selectedwith consideration of the amount of land required and available, favourabletopographical features and in an attempt to avoid or minimize effects on wetlands,waterbodies and other environmentally sensitive areas.Effluent Treatment InfrastructureEffluent from the Tailings Management Facility will be treated prior to discharge tothe receiving environment in order to achieve compliance with the Federal MetalMining Effluent Regulations and the Provincial Environmental Control Water andSewage Regulations. This will include treatment for red water.Access RoadsSeveral access roads will be built including:• A new access road that will extend south from theTrans Labrador Highway to the Project area;• Roads throughout the Project site for service and7

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summarymaintenance vehicles and general access;• Access roads to the fuel unloading area, the Tailings ManagementFacility and tailings pumping system, raw water pumphouse, load-outsilo and concentrate conveyor system and the explosives magazine;• Mining roads, designed specifically for the hauling of ore andwaste from the open pit, including the roads within the pit aswell as the roads required to support mining operations;• Roads within the open pit which will be defined inmore detail as the mine plan is developed.Power / Transmission LinesSeveral options are being considered to provide the electrical power requiredduring the construction phase of the Project.Alderon has discussed its construction power requirements with Nalcor Energy,who will either construct, own and operate a new 46 kV distribution line to thesite or provide power by bringing in diesel generators as required. This optionwould likely involve two 1,200 kW diesel generating units for construction at theconcentrator area, one 800 kW generator at the crusher area, and one 800 kWgenerator located at the site of the mine garage and offices.Rail InfrastructureThe Québec North Shore & Labrador (QNS&L) railway extends for approximately420 km from Labrador West to the Port of Sept-Îles, Québec (as shown on ProjectComponents map).A new railway line will be established to connect the mine site to the existingQNS&L railway network, for a total length of approximately 24 km. The line willconsist of newly constructed (single) track extending south from the existingrailway, past the eastern boundary of the Town of Wabush and then generally westto the mine site. The main track alignment has been designed to match the existingdesign parameters of the QNS&L to provide technical and operational uniformity.A section of loop track will also be constructed in the ore loading area to allowcontinuous slow motion loading of trains and to permit trains to turn aroundwithout detaching locomotives and carrying out switching activities.Other Supporting Infrastructure and EquipmentOther supporting infrastructure and equipment will be required for general miningand processing operations.Key infrastructure and equipment will include:• Crushed Ore Stockpilesand Reclaim System;• Conveyor Systems;• Concentrate Load-out Silo;• Tailings Pipeline;• Reclaim Water Pumphouse;• Runoff Water Retention Basinsand Mine Water Retention Basin;• Gate and Guardhouse;• Administration andMaintenance Offices;• Mine Service Building Warehouseand Employee Facilities;• Pumphouse;• Site Communication Tower;• Explosives Magazine.8

2.2.3 ActivitiesThe Project will involve the construction, operation and eventual closure anddecommissioning of each of the components and facilities described above.Construction activities for the Labrador components of the Project will include thefollowing:• Movement of equipment, materials and personnelto, within and from the site;• Mobilization and installation of required construction infrastructure;• Site preparation (including vegetation clearing,grubbing and excavation as required);• Establishing site buildings and other components and facilities;• Installation of associated systems, equipment and utilities;• Project commissioning.Mining activities will consist of conventional open-pit mining methods. The rockwill be drilled, blasted, extracted, stored and transported to the processing facility.Ore will be recovered and transferred by haul trucks out of the Rose Pit to one ofthe two primary crushing buildings located just to the east of the pit. Activitiesoccurring at the processing plant include crushing, crushed ore storage, grindingand screening, gravity and magnetic concentrating, tailings dewatering andpumping and concentrate conveying and loading activities.The Project will include the development and operation of a railway line whichwill join the existing QNS&L Railway east of the Flora Lake outlet. The rail lineends with a mine loop which includes the concentrate load-out system. The ironore concentrate will be transported by rail using the existing rail and Cliffs railinfrastructure to the Port of Sept-Îles in Pointe-Noire, Québec.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryOnce operation activities cease at the end of the mine life, the closure anddecommissioning phase of the Project will commence.2.2.4 ScheduleConstruction activities will begin after the Project has received all the necessarygovernment approvals and permits. The proposed start date of construction isfall 2013 with completion by fall 2015. The current Project schedule indicatesthat operation of the Project will commence in late 2015 and extend toapproximately 2033.Phase/ActivityFeasibility and DetailedEngineeringEA and Permitting2012 2013 2014 2015 2016 2017 2018 2019 2020-2032Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q42033 2034Construction Phase 1ProgressiveRehabilitationOperationsConstruction Phase 2Closure andDecommissioning9

3.0 SCOPE OF THE ASSESSMENT3.1 Scope of the ProjectThe scope of the Project for the purpose of the environmental assessmentincludes all activities and physical works associated with construction, operation,rehabilitation and closure of the proposed Project.3.2 Factors to be ConsideredThe following factors have been considered as a part of the environmentalassessment:• The need for the Project;• Alternatives to the Project;• The purpose of the Project;• Alternative means of carrying out the Project that aretechnically and economically feasible and the environmentaleffects of any such alternative means;• The environmental effects of the Project, including the environmentaleffects of malfunctions or accidents that may occur in connectionwith the Project and any cumulative environmental effects thatare likely to result from the Project in combination with otherprojects or activities that have been or shall be carried out;• The significance of the environmental effects referenced above;• Comments arising from the public and Aboriginalconsultation and engagement;• Local knowledge and Aboriginal traditional knowledge;• Measures that are technically and economically feasible and that wouldmitigate (lessen) any significant adverse environmental effects of the Project;• The requirements of a follow-up program for the Project;• The capacity of renewable resources that are likely to be significantly affectedby the Project to meet the needs of the present and those of the future.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary3.3 Scope of the FactorsThe assessment of environmental effects focuses on Valued EcosystemComponents (VECs). A VEC is a component or attribute that is important for itsecological, legal, scientific, cultural, economic or aesthetic values.VEC specific factors are discussed in Section 7.11

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary3.3.1 Identification of VECsA total of 13 VECs were identified in the EIS Guidelines for review as a result ofgovernment, Aboriginal persons, stakeholders and general public interests andconcerns. Each VEC is discussed in detail in Section 7.Natural environment VECs are:• Atmospheric Environment (air quality,climate, vibration and noise);• Landforms, Soils, Snow and Ice (landforms,terrain stability, soil quality and quantity,snow and ice as well as the potential for AcidRock Drainage (ARD) and metal leaching);• Water Resources (quality and quantity ofgroundwater and surface water resources);• Wetlands (lands having the water table at, near,or above ground surface, or are saturated longenough to promote wetland aquatic processes);• Freshwater Fish, Fish Habitat, and Fisheries(freshwater fish species and the habitat uponwhich they depend and fisheries activities);• Birds, Other Wildlife and their Habitats,A VEC is a component orattribute that is importantfor its ecological,legal, scientific,cultural, economic oraesthetic values.12

and Protected Areas (migratory and non-migratory speciesthat are potentially feeding, breeding, moving and/or migratingthrough the Project area, their habitat, and Protected Areas);• Species at Risk and Species of Conservation Concern (species of plantor animal, and/or its critical habitat, that is of provincial, national orinternational importance, particularly where the species and/or itscritical habitat is protected under federal or provincial legislation).Human environment VECs are:• Historic and Cultural Resources (archaeological sites, paleontological fossilsites, cultural or spiritual sites and historic buildings and properties);• Current Use of Land and Resources for Traditional Purposes by AboriginalPersons (lands and resources of specific social, cultural or spiritual value tothe Aboriginal persons that are currently used for traditional purposes);• Other Current Use of Lands and Resources (other industrial,residential or commercial uses of the land);• Community Services and Infrastructure (employment,transportation, social , education and health services, safetyand security, and housing and accommodation);• Health and Community Health (human health and wellness and family life);• Economy, Employment, and Business (new economicactivity, workers and local businesses).3.3.2 Spatial and Temporal BoundariesSpatial and temporal boundaries are the study areas and time frames used toinvestigate potential environmental effects of the Kami iron ore mine and railinfrastructure.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummarySpatial boundaries are also known as the study area. The spatial boundariesconsider the geographic extent over which the Project’s environmental effects mayoccur, recognizing that some environmental effects may extend beyond the ProjectDevelopment Area. Spatial boundaries differ by VEC depending on the nature ofpredicted effects.Temporal boundaries consider timing and scheduling of Project activities, and thetime required for recovery from an environmental effect. In general, temporalboundaries for assessment include the construction, operation and maintenanceand decommissioning and reclamation phases of the Project. For most of the VECs,the temporal boundaries for each Project phase consider a construction period ofapproximately two years, operation and maintenance for approximately 17 years,and decommissioning / reclamation approximately one year after operations cease.13

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary4.0 PROJECT ALTERNATIVESThe EIS Guidelines require consideration of alternatives to the Project andalternative means of carrying out the Project that are technically andeconomically feasible.4.1 Alternatives to the ProjectThe need for and purpose of this Project is to develop the iron ore depositswithin the Kami Property and to produce iron ore concentrate suitable for sale tointernational markets.Addressing the overall, worldwide requirement for iron ore could potentially beaddressed through other development projects or initiatives, which may alsoprovide associated economic benefits to the regions and jurisdictions in which theyare developed. With the exception of this proposed Project, however, no othersuch alternatives are within the ability and responsibility of Alderon. The onlyalternative to Alderon’s construction and operation of the Kami Project is a decisionto not proceed with this development – the “no-go” decision.The proposed Project provides a technically feasible, economically viable andattractive, and environmentally and socially responsible means of addressing theidentified need for and purpose of the development and one which can and willbe planned and implemented in a manner that avoids or reduces potential adverseenvironmental effects and optimizes socio-economic benefits.4.2 Alternative Means of Carrying out the ProjectDescription of Alternative MeansThe environmental assessment process allows for the identification, analysis andevaluation of different potential project concepts and approach options, in orderto include environmental considerations into project planning at an early stage andpotentially influence Project design. The EIS considers possible alternative meansof carrying out the Project that are technically and economically feasible (shown intable below).14

Technical and Economic Feasibity of Alternative Means of Carrying out the ProjectProjectComponentTailingsManagementWaste RockStorage(managementand location)Transportation(includingalternative railroutes)AlternativeConsideredOption 1: tailingsdisposal in open pitOption 2: tailingsdisposal in naturalwaterbodiesOption 3: conventionaltailings storagein an engineeredimpoundmentOption 4: dry stackingof dewatered tailingsOption 5: co‐disposalof tailing and wasterockOption 1: co‐disposalof tailings and wasterockOption 2: disposal innatural waterbodiesOption 3: utilizingwaste rock asconstruction aggregateEconomic & Technical Feasibility• To be investigated at a later date at a later stage of theproject, after the open pit has been established• Not considered to be feasible or environmentally acceptable• Technically and economically feasible, usingeffective and proven technology• Environmental issue associated with dust generation• Based on technical / operational aspects, environmentalissues, socioeconomic issues and economic implications,this option was not considered acceptable based onthe physical site constraints and volume of tailingsproduced at a substantial distance from the pit area• The locations of Rose North and Rose South wasterock disposal areas were selected with considerationof ensuring adequate space and topography, as wellas based on environmental issues and input receivedby Alderon throughout its consultation processes• Not considered to be an environmentally acceptable option• Further testing of waste rock must be completed to determinefeasibility of using this material as construction aggregatePreferredOptionOption 1: railway • Economically and technically feasibleOption 2: pipelineOption 3: roadwayPower Supply Option 1: new 46kV distribution linebringing power directlyto the plant mainsubstationMiningMethodsOption 2: powerprovided by dieselgeneratorsOption 1: open pitminingOption 2: undergroundmining• Require high initial capital cost for constructionwhen compared to rail transport• Additional power required to operate the pumpingsystems necessary to keep the line operational• Difficult ground conditions for pipeline constructionand operation presents technical challenges• The existing route is inadequate (single lane each way,partially paved, route is indirect) and would lead tofinancially prohibitive operating costs for the Project• Preferred option for economic reasons• Preferred option for environmental reasons (due to theair emissions associated with diesel generating units)• Not preferred due to environmental concernsassociated with air emissions that would beassociated with the diesel generating units• Used extensively in similar iron ore mining andother operations in Labrador and elsewhere• Proven to be effective and viable process for use in such operations• Not considered to be an economically feasible alternativeKami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary15

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummarySelection of a Preferred Alternative MeansThe selected Project components, noted above, were identified as the preferredtechnically and economically preferred option with the least potential for effects tothe environment from Project activities. The environmental effects of the preferredoptions are assessed in the EIS.16

5.0 CONSULTATION5.1 Public and Aboriginal Consultation andEngagement Activities undertaken for the EASince the acquisition of the Kami Property in December 2010, Alderon has workedto establish open and transparent communication with various potentiallyinterested or affected individuals and organizations. Alderon’s approachincludes engagement with Aboriginal groups, public stakeholders and regulatoryagencies. The objectives of this consultation and engagement program wereidentified in accordance with the EIS Guidelines (CEA Agency and DOEC 2012),the Newfoundland and Labrador Environmental Protection Act (NLEPA), and theCanadian Environmental Assessment Act (CEAA).The overall objectives of the consultation and engagement program are to:• Provide Project information and updates on a regular basis;• Engage Aboriginal groups and stakeholders throughout the environmentalassessment (EA) process and during the life of the Project;• Identify issues of concern with the Project early in the process;• Adapt the Project design, where possible, to avoid andmitigate adverse environmental effects; and• Demonstrate how issues and concerns raised duringengagement activities have been addressed in the EIS.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryAlderon’s consultation and engagement program for the EA includes five phasesshown below in an overview of the EA timeline, including associated consultationand engagement phases and program milestones.Timeline for Consultation and Engagement ProgramPre-Project Regitration• Initial informationsharing andrelationship building2011 20122013 OngoingPost-RegitrationProject RegistrationOctober 17, 2011EA Notice of CommencementJanuary 27, 2012• Project informationsessions• Receive comments onthe Project• Identify issuesEIS Pre-Submission• Project information sessions• Receive comments on the Project• Identify issuesEIS SubmissionEIS Post-Submission• Project information sessions• Respond to issues and concernsEA ApprovalPost-EA• Share information and address concernsthroughout the life of the ProjectOngoing Aboriginal Engagement and Public Consultation17

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryPublic and Regulatory Consultation ActivitiesPublic stakeholders engaged by Alderon include residents of the towns of LabradorCity, Wabush, Fermont and Sept-Îles. In addition to these stakeholders, Alderon hasalso engaged other potentially affected and/or interested stakeholders includingprovincial and federal government agencies and departments, non-governmentalorganizations, economic development organizations, and outdoor recreation usersand outfittersPublic consultation activities include information sharing, general consultation withcommunity members, and key stakeholder meetings. In particular:• Public notices were created to share information with the generalpublic and those potentially affected by the Project;• A Project website was created to provide Project information, EAdocumentation, notifications, and consultation materials and providedan area for stakeholders to submit contact information and comments;• Public Information Sessions were held to provide information to thegeneral public and other interested stakeholders and receive feedback;• Key stakeholder meetings were held to inform keystakeholders on Project design and EIS studies, and identifyissues with the Project to be included in the EIS.Consultation with federal and provincial regulatory agencies is an importantcomponent of EIS development. Alderon’s approach to regulatory consultation is toestablish and maintain transparent dialogue with federal and provincial regulatorsthroughout development of the EIS. Consultation activities include ongoinginformation updates and meetings, including sharing stakeholder and Aboriginalissues as they arise. In addition, Alderon met with reviewing agencies during thedevelopment of the EIS to present baseline studies, study methodology and effectsassessment for each component chapter. This approach is aimed at informingreviewers, and obtaining feedback early in the process.Issues identified most frequently during public and regulatory consultation include:• Public participation;• Potential effects from dust;• Potential effects on cabins;• Potential noise effects;• The availability of housing for workers.18

Frequency of Issues Identified During Public Consultation ActivitiesCommunity Servicesand InfrastructureConsultation / EA ProcessEconomy, Employmentand BusinessCurrent Use of Landsand ResourcesAtmosphericEnvironmentHealth andCommunityHealthWaterResourcesFrequency of Issues10 20 30 40 50 60 70 80• Availability of Housing for Workers 46• Community Infrastructure 26• Community Services 22• Increased Road Traffic 21• Temporary Construction Camp 20• Recreational Infrastructure 14• Cumulative Effect on CommunityServices and Infrastructure9• Increased Railway Traffic• Light7• Health Services• Increased Air Travel5• Public Participation 77• Aboriginal Engagement 30• Project Description / Registration 15• Translation of Project Information 12• Project Schedule 6• EA Jurisdiction 4• EIS Guidelines 3• EA Schedule 2• Financial Capacity forConsultation on the Project1• Aboriginal Employment andBusiness Opportunities32• Availability of Local Workers• Local Economy22• Apprenticeship and Training• Diversity in the Workplace 18• Local Businesses 13• Cumulative Effects on Economy,Employment and Business10• Financial Benefit for Municipality 2• Business Access 1• Cabins 39• Recreational Activities 19• Snowmobile Trails 11• Land Use Activities 8• Fishing Activities 7• Hunting Activities 6• Property Value• Access to Property5• Trapping 4• Dog Sled Trails• Wood Harvesting1• Travel Routes• Dust 52• Noise 38• Air Quality 20• Cumulative Effects onAtmospheric Environment4• Greenhouse Gas Emissions 1• Quality of Life 33• Visual Aesthetics 29• Human Health 21• Safety 11• Cumulative Effects on Healthand Community Health9• Water Quality 36• Waterbodies 24• Water Supply 21• Water Management 10• Cumulative Effects on Water Resources 5Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary19

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryFrequency of Issues Identified During Public Consultation Activities (cont’d)Project Design and LocationCurrent Useof Lands andResources byAboriginal Personsfor TraditionalPurposesBirds, OtherWIldlifeand TheirHabitat, andProtectedAreasProject PhasesWetlands• Location of Tailings Impoundment 18• Location of Rail 16• Availability of Power 12• Economic Feasibility• Location of Waste Rock Piles• Location of Access Road• Location of Transmission Line 8• Secondary Processing of Iron Ore 4• Accidents and Malfunctions 3• Location of Concentrate Storage Facility 2• Alternative Sources of Energy 1• Interaction with ExistingAboriginal Rights or Title• Traditional Land Use Activities by Aboriginal 18• Cumulative Effects on Use of Landsand Resources for Traditional3Purposes by Aboriginal Persons• Wildlife Species 22• Parks and Protected Areas• Waterfowl6• Wildlife Habitat 4• Cumulative Effects on Wildlife Species 3• Post Closure 9• Engineering and Project Design 8• Exploration• Monitoring and Follow-up6• Mining Operations 4• Construction 1• Effects on Wetland Stewardship Areas 16• Wetlands 8Frequency of Issues10 20 30 40 50 60 70 80921FreshwaterFish, FishHabitat andFisheriesLandforms,Soils, Nowand IceSpecies atRisk andSpecies ofConservationConcernHistoricandCulturalResources• Fish Habitat 12• Cumulative Effects on Fish and Fish Habitat 2• Fish Population 3• Reclamation & Rehabilitation 8• Cumulative Effects On Landforms,Soil, Snow And Ice2• Snow and Ice• Acid Rock Drainage 1• Caribou 6• Cumulative Effects on Species at Risk• Species at Risk• Archaeological Sites 5• Burial Sites 1120

Aboriginal Engagement ActivitiesAlderon recognizes the importance of building relationships based on mutual trustand respect with Aboriginal groups which may be affected by the Project in orderto achieve mutually beneficial outcomes. Alderon is committed to ensuring thatpotentially affected Aboriginal groups and communities are appropriately engagedso that Alderon can identify, understand and address any potential adverse effectsof the Project on those groups and communities and their current use of land andresources for traditional purposes.Alderon’s approach to engagement with Aboriginal groups is guided by itsAboriginal Relations Policy. Pursuant to the Aboriginal Relations Policy,Alderon will:• Acknowledge potential or established aboriginal or treaty rightsand comply with the requirements of any applicable treaties,laws, regulatory measures and governmental policies;• Provide opportunities for aboriginal groups to share traditional knowledgeand information on traditional land and resource use in the project area;• Develop an effective, respectful and meaningful engagement process; and• Work cooperatively and collaboratively with aboriginal groups toidentify Project effects and develop and implement appropriatemitigation measures, including, where appropriate, the negotiation ofagreements to address adverse effects and provide access to benefits.Alderon has engaged with those Aboriginal groups and communities who havetreaty rights or recognized or asserted Aboriginal rights or Aboriginal title(collectively referred to as “Aboriginal Interests”) and who may be affected by theProject. In order to determine the existence of such Aboriginal Interests, Alderonhas reviewed a broad range of information in order to gain a general understandingof the nature of known Aboriginal Interests in the Project and to identify theaboriginal groups and communities which will be engaged by Alderon.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryAlderon has identified five Aboriginal groups with Aboriginal Interests whichmay be affected by the Project. These groups which form the participant list forAlderon’s Aboriginal engagement program are:• Innu Nation;• NunatuKavut Community Council;• Uashat mak Mani-Utenam;• Matimekush-Lac John; and• Naskapi Nation of Kawawachikamach.Alderon has made significant efforts to engage with each of these Aboriginalgroups. These efforts are based on Alderon’s Aboriginal Engagement Strategy andAction Plan which establishes the framework for a coordinated and comprehensiveengagement process which is consistent with the requirements of any applicabletreaties, laws, regulatory measures and governmental policies, including the EISGuidelines. The engagement process commenced prior to Project registration andwill continue throughout the life of the Project until closure and decommissioning.21

• Mitigation and Avoidance: Alderon will provide opportunities toAboriginal groups to be consulted on the development of mitigationor avoidance measures where, as a result of information generatedthrough engagement, it is determined that the Project is likely tohave adverse effects upon Aboriginal Interests or otherwise adverselyaffect traditional land and resource use. Such mitigation or avoidancemeasures may include environmental monitoring, land and culturalprotection measures and the negotiation of benefits agreements.Alderon will incorporate information gained during engagement intoProject planning and execution and will adapt plans as necessary totake into account the views of Aboriginal groups and communities.Alderon’s engagement efforts have enabled the various Aboriginal groups toidentify issues of particular concern. Issues most frequently identified by Aboriginalgroups through engagement are:• Aboriginal employment and business opportunities;• Aboriginal engagement;• Potential interaction with existing Aboriginal rights or title;• Potential Effects of the Project on traditional land use activities; and• Potential effects of the Project on Wildlife.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary23

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryFrequency of Issues Identified During Aboriginal Engagement ActivitiesNumber of Times Issue was Raised5 10 15 20 25• Aboriginal Employment and Business Opportunities 24• Aboriginal Engagement 20• Interaction with Existing Aboriginal Rights or Title 17• Traditional Land Use Activities by Aboriginal Persons 14• Wildlife Species 7• Caribou 6• Apprenticeship and Training• Diversity in the Workplace• Exploration 5• Hunting Activites• Increased Railway Traffic• Trapping 4• Cabins• Cumulative Effects onWildlife Species• Project Description / Registration 3• Availability of Power• Cumulative Effects on useof Lands and Resourcesfor Traditional Purposesby Aboriginal Persons• Dust• Land Use Activities• Access to Property• Accidents and Malfunctions• Cumulative Effect on CommunityServices and Infrastructure• Cumulative Effects onFish and Fish Habitat• Economic Feasibility• Engineering and Project Design• Financial Capacity forConsultation on the Project• Fishing Activities• Human Health• Local Economy• Location of Rail• Location of TailingsImpoundment• Post Closure• Quality of Life• Reclamation and Rehabilitation• Temporary Construction Camp• Waterbodies• Wildlife Habitat• Location of Transmission Line• Mining Operations• Project Schedule• Property Value• Public Participation• Recreational Activities• Safety• Species at Risk• Translation of ProjectInformation• Travel Routes• Water Quality• Water Resources• Water Supply2 21Post-Submission of EISFollowing submission of the EIS, Alderon will continue Aboriginal engagement,and public and stakeholder consultation activities. Alderon will continue effortsto engage with potentially affected and/or interested Aboriginal communities,including outreach to Band Councils, capacity building, and community meetingswhere identified as appropriate by community leaders.24

6.0 EXISTING ENVIRONMENTThe proposed Kami Project in located in western Labrador, within the LabradorCity and Wabush Municipal Planning Areas and the Hyron Regional EconomicZone. Mineral exploration, mining and associated industrial activities have beenongoing in the region since the late 1950s, and have become the backbone of itseconomic sustainability. The Kami property is flanked by several operating iron oremines (IOC, Wabush Mines and ArcelorMittal) and will contribute strongly to thecontinued economic development and growth of the region by providing significantemployment and business opportunities for the next thirty years.The Project area is located to the immediate southwest of the Towns of Wabushand Labrador City and the existing mining and mineral processing operations inLabrador West, and to the northeast of the Town of Fermont, Québec. These aremodern, vibrant communities, with relatively high employment rates and incomelevels amongst their residents, and which provide a wide range of services andinfrastructure. The relatively high standards of living in this region have resultedfrom the mining developments and associated activities that have characterizedthe economies of the area over the past several decades. Although it is recognizedthat recent growth due to the expansion of mining activities in the region haveseen some issues related to the availability and affordability of housing and otherservices and infrastructure as well as other socioeconomic issues in the area, theoverall quality of life of its residents remains relatively high.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary25

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryThe existing (baseline) condition of the environment within and near the Projectarea is the result, and reflects the effects, of other past and on-going humanactivities in the region. Regional ambient air quality monitoring indicates thatthe average air quality in the region is good overall, with SO2 and NO2 ambientconcentrations being below applicable standards and with total suspectedparticulate (TSP) levels occasionally exceeding guidelines. Baseline water qualitymonitoring data similarly shows that existing surface water quality is good,with several parameters occasionally and slightly exceeding ecological waterquality guidelines.The biophysical environment in which the Project lies is within the Mid SubarcticForest (Michikamau) Ecoregion – ED432 Ecodistrict of western Labrador. Habitattypes common to western Labrador are found throughout the Project area. Thesehabitat types support a wide range of wildlife species that are common throughoutthe region.Species at risk and species of conservation concern which have been observed inthe Project area include: the Olive-sided Flycatcher (Threatened), and the RustyBlackbird (species of special concern). There were no observations of any plantspecies listed as species at risk within the Project area. Eight plant species ofconservation concern were recorded in the Project area, occurrences of all eightspecies were also recorded outside the vicinity of the Project. No caribou wereobserved in proximity to the Project area.Wetlands cover a sizable proportion of the natural landscape of Labrador and arecommon throughout the Project area. Both Labrador City and Wabush have signedMunicipal Wetland Stewardship Agreements with the provincial governmentand Eastern Habitat Joint Venture, which require the incorporation of wetlandconservation in the scope of municipal planning. Each municipality was requiredto designate wetlands areas with their municipal planning areas as HabitatManagement Units (Town of Labrador City and Eastern Joint Habitat Venture 2010;Town of Wabush and Eastern Habitat Joint Venture 2010). The Project has beendesigned to avoid impacts on the Management Units wherever possible, however,the ore body intersects the Pike Lake South Management Unit. No unique habitatfeatures were identified within the management unit or elsewhere within theproject area.Fish species and habitat common to western Labrador are present within theProject area. Recreational fisheries are conducted throughout the region and inclose proximity to the Project area. There were no observations of any fish specieslisted as species at risk within the Project area, and no Commercial or Aboriginalfisheries have been identified in or near the Project area.Current land and resource use in the vicinity of the Project area includes municipalplanning, industrial activities, cabin use, hunting and trapping, angling, woodharvesting, berry picking, snowmobiling, and boating among other recreationalactivities. Due to the close proximity to the towns of Labrador City and Wabush,recreational land use in this area is extensive. A number of cabins have beenidentified within the Project area.26No aboriginal communities exist in close proximity to the Project, the closest beingSchefferville, located approximately 200 km to the north. However, the Project islocated in an area which five aboriginal groups assert as their traditional territory.

There are no treaties or settled land claims which overlap the Project area and,although residents of Labrador West engage in recreational land and resourceuse activities throughout the region, based on the information available, thereis no evidence of current use of lands and resources for traditional purposes byAboriginal Persons in or immediately adjacent to the Project area. Additionally, noHistoric and Cultural resources have been identified in the Project area.The Environmental Impact Statement provides detailed descriptions of the existingbiophysical and socio-economic environments that could be affected by the Projectfor each relevant VEC.Details on each specific environmental component are found in the detailed VECanalysis. Baseline descriptions for each VEC are based on an ecosystem approachand are provided as appendices.Stand alone baseline studies which describe the existing environment in moredetail to support the evaluation of environmental effects, the development ofmitigation measures and monitoring and follow up programs have beenconducted for:• Freshwater fish, fish habitat and fisheries;• Water resources (fresh water quality and quantityfor groundwater and surface water);• Wetlands;• Air quality monitoring; and• Socio-economic (including housing, labour force, communityservices, employment demands, local infrastructure).Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryDuring the development of these baseline studies, government and nongovernmentagencies have been engaged in the design and methodology for thecollection of data to help ensure a thorough and comprehensive basis for theenvironmental assessment. The stand alone baseline studies are incorporated intothe EIS document as appendices.27

Proportion of Issues Identified During Aboriginal Engagement andPublic Consultation ActivitiesKami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary29

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryOverview of Environmental Assessment MethodScoping of the AssessmentExistingConditionsSTEP 1STEP 2STEP 3STEP 4STEP 5STEP 6VEC SelectionRationale for Selection, Issues Identification, Regulatory SettingProject Interactions with the Environment• Identification of Environmental Effects• Screening of Project-Environment Interaction• Selection of Measurable ParametersIdentification of EA BoundariesEstablish Standards or Thresholds for Determining(also known as Significance Criteria)Describe Existing ConditionsAssessment of Project-Related Environmental Effects• Description of Project Environmental Effects• Mitigation of Project Environmental Effects• Characterization of Residual Project Environmental Effects• Assess and Respond to Issues Raised by Stakeholder GroupsOngoingConsultation andIssue ScopingAssessmentSTEP 7Assessment of Cumulative Effects• Screening of Cumulative Effects• Identification of Other Projects and Activities• Characterization of Residual Cumulative EffectsRepeat forEach VEC andEnvironmentalEffectSTEP 8Determination of Significance• Residual Project-Related Environmental Effects• Residual Cumulative EffectsConclusionsSTEP 9STEP 10Follow-Up and MonitoringSummary30

7.2 Valued Ecosystem ComponentsThe environmental effects of the Project have been assessed in accordance with allapplicable environmental assessment regulations, the EIS Guidelines and acceptedindustry best practices. A summary of the results of the environmental assessmentfor each VEC is presented below.7.2.1 Atmospheric EnvironmentAtmospheric environment considers ambient air quality and the acoustic and visualenvironments (noise, vibrations, light) within the vicinity of the Project. Alderonconducted baseline monitoring programs for air quality and noise to characterizeexisting conditions of the atmospheric environment that could be affected bythe Project. In addition to using data from existing monitoring stations, Alderoninstalled monitoring stations on the shore of Long Lake, in Wabush and in Fermont.This data was used to predict dispersion of dust and noise that may be generatedby the Project.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary31

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryAtmospheric Environment Local and Regional Study AreasRegional Study AreaLabrador City500Wabush MineProposedPowerlineDuley Lake Provincial(Nalcor)Park ReserveLocal Study AreaRose NorthWaste RockDisposalAreaRose PitTailingsManagementFacilityRose SouthWaste RockDisposalAreaLicensesFermontWabush MineWabushProposedAccess RoadProposed Railway±LABRADORQUÉBECFIGURE ID: ALD_ST_6750 2 4KilometresIssuesCLIENTIssues raised during consultation included Project-related changes in air quality,DRAWING NAMEcontrol of dust, dust from tailings, noise and greenhouse gas emissions. Alderonhas measured baseline noise and air emissions and predicted Project-basedemissions in order to design the Project to meet federal and provincial guidelinesand address stakeholder concerns. Alderon will implement mitigation, such asprogressive rehabilitation, to manage atmospheric emissions and will continueto monitor effects as appropriate. In response to issues raised by stakeholders,Alderon has also moved the Rose South Waste Rock Disposal Area approximately 5km east, to minimize potential effects on the Town of Fermont. A complete recordof all comments with responses is included in Appendix B.CLIENT:DRAWING TITLE:32

Frequency of issues raised during engagement activitiesNumber of Times Issue was Raised60504030201005238Dust Noise Air Quality Cumulative Effectson AtmosphericEnvironment2041Greenhouse GasEmissionsPotential Environmental EffectsThe Project is located in an area where mining and rail activities currently occur.The proposed Project will temporarily contribute to emissions, noise andvibration and lighting during Project construction and longer term air andgreenhouse gas emissions, noise, vibration and industrial lighting during theoperation of the Project.Construction activities will result in emissions of air contaminants includingparticulate matter (dust) and combustion gases through the combustion of fuel inconstruction equipment. The emissions of criteria air contaminants during Projectconstruction will be temporary in nature and are expected to be within regulatoryobjectives, standards and guidelines.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryConstruction and operation activities will produce noise emissions. Thecommunities of Fermont, Labrador City and Wabush are separated from thefacilities by distances of the order of 5 to 10 km, and are unlikely to experiencenoise resulting from the civil works. The cabins on Long Lake and Riordan Lake arewithin 5 km, and within a few hundred meters in certain cases and will experiencesome elevated noise levels. The south side of Wabush may experience noisefrom rail traffic.The vibration related to drilling and blasting has been evaluated for the Project.Due to the distance from the Project site to the nearest receptors, vibration fromthe operation of heavy construction equipment will generally not be of concern.Light emissions during Project operation will result from a number of miningactivities. Light from the cluster of Project facilities at the south end of Long Lakewill be generally visible to the cabins on the west shoreline.33

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryMitigation MeasuresAlderon will implement mitigation measures to reduce significant adverse effectson properties. Key mitigation measures include progressive rehabilitation, useof dust suppressants, use of covered conveyors as required, adherence to acomprehensive equipment maintenance program and monitoring programs.Residual Environmental EffectsGiven the implementation of mitigation measures, the Project is not likely to resultin significant adverse environmental effects under normal operating conditions.7.2.2 Landforms, Soils, Snow and IceLandforms, Soils, Snow and Ice includes consideration of landforms, terrainstability, soil quality and quantity, snow and ice as well as the potential for AcidRock Drainage (ARD) and metal leaching (ML). Existing information was used todevelop this assessment, including results from an ecological land classification,bedrock geology mapping, terrain mapping, permafrost data and climatic data fromEnvironment Canada. In addition, digital imagery was used in the interpretation oflandforms, geomorphic processes (such as seepage), drainage, and soil conditions.The assessment of potential ARD/ML effects is based on historical data fromsimilar mines, monitoring of existing mines and testing of the geological materialscollected from the site.The existing environment in the Project Development Area has mixed bedrockgeology. The Project area is composed mainly of till, deposited directly by iceduring the last glaciation, which covered most of Labrador. Only one unique orvaluable landform feature has been identified within the Local Study Area. Anapproximately 5 km long esker runs along the west side of Waldorf River, east ofthe Rose South Waste Rock Disposal Area. The esker varies in width from 50 m to34

285 m and is between 5 to 20 m above the Waldorf River. Acid Base Accountingindicated that the waste rock is classified as non-acid generating.Landforms, Soils, Snow and Ice Local and Regional Study AreasRegional Study AreaRose NorthWaste RockDisposalAreaRose Pit500Local Study AreaDuley Lake ProvincialPark ReserveRose SouthWaste RockDisposalAreaLabrador CityWabush MineTailingsManagementFacilityProposedPowerline(Nalcor)LicensesWabushProposed RailwayWabush MineProposedAccess Road±Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryFermontLABRADORQUÉBECFIGURE ID: ALD_ST_6710 2 4KilometresIssuesCLIENTIssues identified by participants relating to landforms, soil, snow and ice are shownDRAWING NAMEin Figure 13.5. Participants identified reclamation and rehabilitation, cumulativeeffects, snow and ice, and acid rock drainage as issues of concern. To addressthese issues, Alderon will minimize the use of the esker, implement progressiverehabilitation, develop a Rehabilitation and Closure Plan and develop a BlastingPlan. A complete record of all comments with responses is included in Appendix B.CLIENT:DRAWING TITLE:35

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryFrequency of issues raised during engagement activitiesNumber of Times Issue was Raised98765432108Reclamation andRehabilitation2 2Cumulative Effects onLandforms, Soil,Snow and IceSnow and Ice1Acid Rock DrainagePotential Environmental EffectsProject-related environmental effects on Landforms, Soils, Snow and Ice includechanges in landforms and terrain stability, change in soil quality and quantity,changes in snow and ice and acid rock drainage/metal leaching.Construction activities will result in alterations to existing landforms and existingdrainage regimes within the mining and processing areas. The construction of theroads, associated facilities and rail line will also result in alterations to the currentlandforms; however given the relatively gently undulating, rolling and inclinednature of the terrain coupled with overburden of up to 51 m in depth, it is notanticipated that any landforms will be lost.Terrain stability is generally an issue for most mining projects. From a surficialgeology perspective, no landslides or any evidence of slow mass movement wereobserved from an examination of existing aerial photographs.Site preparation and construction activities have the potential to result in achange in soil quality and quantity. Airborne deposition of dust associated withconstruction has the potential to change soil quality. However, the parent geologicmaterial contains iron, and therefore the deposition of dust composed of ironparticulates will not adversely affect soil quality on upland soils.Construction of the mine site and associated infrastructure will have thepotential to affect snow distribution and subsequent drifting of snow. Much ofthis will be caused by changes in the microtopography which influences winddirection and speed.Effects of acid rock drainage/metal leaching are not likely based on testing to dateand experience with other operations.Mitigation MeasuresWith the implementation of standard mitigation (such as maintenance of naturaldrainage patterns), shallow landslides are not anticipated.Changes in soil quantity will be minimized through the stockpiling of peat andtopsoil. These stockpiled soils will be used to reclaim the site progressively and atthe time of mine closure. Effluent discharge will be treated prior to release to thereceiving environment, minimizing subsequent effects to soil quality.Effects to snow deposition and drifting will be mitigated through the use of snow36

fences to control snow drifting in critical areas. Blasting will be managed so that thevibrations will not affect ice cover of nearby lakes.Residual Environmental EffectsGiven the implementation of mitigation measures, the Project is not likely to resultin significant adverse environmental effects under normal operating conditions.7.2.3 Water ResourcesWater Resources combines both groundwater resources and surface waterresources. Both are important components of the hydrologic cycle and aneffect on one can influence the other. A baseline assessment of both surfacewater and groundwater was completed for this VEC. A hydrological assessmentcharacterized the baseline conditions in watersheds potentially affected by theProject and included a regional hydrological information review, a climate andprecipitation assessment, a water balance assessment, hydrological monitoring andhydrological modeling. Groundwater monitoring wells have been installed at andnear the proposed open pit location and elsewhere throughout the Project area.Groundwater baseline data has been derived from exploration drilling programs,site-specific hydrogeological testing, automated and manual groundwater levelmonitoring, and water quality sampling throughout the Project area.The Rose iron ore deposit lies within a northeast orientated drainage systemwhich includes four small ponds and Rose Pond. Regional groundwater flow inthe area generally follows topography from the upland areas toward the adjacentvalleys, with short (typically less than a few kilometers) travel paths from point ofrecharge to point of discharge. Local groundwater flow is influenced by topography.Groundwater recharge from precipitation and runoff is typically limited to the latespring and summer when the ground is not frozen (May to October).Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary37

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryWith respect to surface water resources, a system of watercourses and lakes withinthe Local Study Area eventually discharge into Wabush Lake. Drainage across theLocal Study Area is generally directed north and east through a series of wetlands,lakes and connecting streams.Water Resources Local and Regional Study AreasRegional Study Area500Labrador City±Local Study AreaWabush MineWabushWabush MineDuley Lake ProvincialPark ReserveProposedPowerline(Nalcor)ProposedAccess RoadRose NorthWaste RockDisposalAreaRose PitTailingsManagementFacilityProposed RailwayRose SouthWaste RockDisposalAreaLicensesFermontLABRADORFIGURE ID: ALD_ST_672QUÉBEC0 2 4KilometresCLIENT:CLIENTIssuesKey issues identified during the EIS consultation DRAWING NAME and engagement programinclude contamination of water bodies and water supply, degradation of surfaceand groundwater water quality, water management and cumulative effects onwater resources. In response to these issues, Alderon will implement mitigationmeasures such as implementation of a Water Management Plan, effluenttreatment (including red water treatment) and dust control. A complete record ofall comments with responses is included in Appendix B.DRAWING TITLE:38

Frequency of issues raised during engagement activitiesNumber of Times Issue was Raised4035302520151050362421Water Quality Waterbodies Water Supply Water Management Cumulative Effects onWater ResourcesPotential Environmental EffectsWater resources may be affected during the construction, operation anddecommissioning phases of the work. The primary direct Project related effectson groundwater resources will include large scale pumping and dewatering duringoperation of the open pit mine, and localized changes to groundwater quality inthe vicinity of plant facilities, petroleum storage tanks, tailings impoundment andwaste rock areas.Alterations to the land surface resulting from Project facilities (such as the openpit and Tailings Management Facility) and activities affecting surface water (suchas water withdrawal and treated effluent discharge) will be the primary drivers ofeffects to surface water resources. Surface water effects relate to potential changesin receiving water hydrology, water quality and sediment quality. Changes to flowand water quality relate to changes to the drainage, infiltration and groundwaterdischarge characteristics, Project water withdrawal and uses, and return of treatedeffluent to receiving waters.105Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryMitigation MeasuresBest management practices will be used to manage erosion and sedimentation,drainage, and dewatering to minimize effects on groundwater and surface waterresources. For example, effluent will be treated, including control of red water, tomeet MMER and the NL Environmental Control Water and Sewage Regulationsdischarge limits. Perimeter ditches will be constructed around the open pit andwaste rock disposal areas to collect and divert runoff. Groundwater levels betweenthe open pit mine and identified groundwater users will be monitored throughoutthe life of the Project. Optimized water withdrawal and re-use, and restoration ofwater balance conditions and natural drainage patterns will further help mitigateadverse effects on surface water quality and quantity.Residual Environmental EffectsGiven the implementation of mitigation measures, the Project is not likely to resultin significant adverse environmental effects under normal operating conditions.39

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary7.2.4 WetlandsWetlands are characterized as lands having water at or near the ground surface andinclude bogs, fens, marshes, swamps, and shallow water wetlands. Wetlands wereselected as a VEC because of the potential for the Project to interact with wetlandenvironments and because of the relationship between this VEC, wildlife and otherbiological and physical environments. The majority of baseline data were collectedthrough surveys of the Local Study Area which included detailed vegetationsurveys, wetland inventories, and rare plant surveys.Wetlands are relatively common throughout the Regional Study Area and LocalStudy Area; fens and marshes are the most abundant wetland type.Wetlands Local and Regional Study AreasRegional Study Area500Labrador CityWabush MineWabushWabush Mine±Local Study AreaDuley Lake ProvincialPark ReserveProposedPowerline(Nalcor)ProposedAccess RoadRose NorthWaste RockDisposalAreaRose PitTailingsManagementFacilityProposed RailwayRose SouthWaste RockDisposalAreaLicensesFermontLABRADORQUÉBECFIGURE ID: ALD_ST_6740 2 4KilometresCLIENT:DRAWING TITLE:CLIENTDRAWING NAME40

IssuesThe main issue of concern raised during the consultation process was the potentialeffect of the Project on wetland stewardship areas. Alderon is in the process ofpursuing a Corporate Stewardship Agreement with the municipalities and theProvince (through the Eastern Habitat Joint Venture) to address the effects of theProject on Management Units. A complete record of all comments with responsesis included in Appendix B.Frequency of issues raised during engagement activitiesNumber of Times Issue was Raised18161412108642016Wetland Stewardship Areas8WetlandsPotential Environmental EffectsEffects on wetlands will mostly occur during the construction phase. Constructionactivities have the potential to result in the alteration or loss of wetland supplyand function. Site preparation (including clearing, excavation, material haulage,grading, and removal of overburden and stockpiling) will have the largest effect onwetland quality and quantity. Construction of access roads, railways, watercoursecrossings, site buildings and other associated infrastructure may also contributeto the potential loss or alteration of wetlands. However, no wetland types will belost completely as a result of Project activities. Project effects on wetlands functionare expected to be of limited environmental consequence, as no long-term or farfutureloss of wetlands function in the Local Study Area or the Regional Study Areais expected. Of the 8,918 ha of wetlands identified within the Regional Study Area,less than six percent will be lost.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryMitigation MeasuresEffective Project planning, design, and the application of known and provenmitigation measures will be implemented as part of the Project to avoid orminimize the environmental effects on wetlands. General measures to minimizeadverse effects will be addressed through a Project-specific EnvironmentalProtection Plan developed for the Project prior to start of the construction phase.Newfoundland and Labrador’s wetland habitat stewardship program “workswithin the context of the Eastern Habitat Joint Venture to secure, enhance andrestore important fresh and saltwater wetlands for waterfowl and other wildlifespecies” (Government of Newfoundland and Labrador 2011b). Alderon is in theprocess of pursuing a Corporate Stewardship Agreement to further mitigateProject effects on wetlands41

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryResidual Environmental EffectsGiven the implementation of mitigation measures, the Project is not likely to resultin significant adverse environmental effects under normal operating conditions.7.2.5 Freshwater Fish, Fish Habitat and FisheriesFish, Fish Habitat and Fisheries includes the populations and associated habitatsfor all freshwater fish species that may or will be affected by the Project. Fishinclude all species at any life stage, while fish habitat is defined as all productiveand migratory fish habitat areas that may be affected by the Project. Productivefish habitat includes all areas that provide an important function in sustaining thelife processes of fish including spawning grounds, nurseries, rearing areas, foragingareas and migration corridors. Fisheries are defined as the commercial, Aboriginal,subsistence, and recreational fisheries. However, because there are no reportedAboriginal, commercial or subsistence fisheries, only recreational fisheries arerelevant to the assessment.In-field studies were conducted in many of the lakes and streams in the ProjectDevelopment Area. These field studies were augmented by information fromother sources to provide a characterization of the waterbodies in the Local StudyArea and Regional Study Area. Species observed included lake chub, slimy sculpin,brook trout, pearl dace, and longnose dace. None of the fish species observedprovincially or federally listed species listed under the Species at Risk Act or theprovincial Endangered Species Act.Environmental effects to Freshwater Fish, Fish Habitat, and Fisheries are most likelyto occur within the Project Development Area and Local Study Area, which includeseveral drainages that eventually flow into Little Wabush Lake, and Wabush Lake.42

Freshwater Fish, Fish Habitat and Fisheries Local and Regional Study AreasRegional Study Area500Local Study AreaDuley Lake ProvincialPark ReserveLabrador CityWabush MineWabush MineWabushProposedPowerline(Nalcor)ProposedAccess Road±Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryRose NorthWaste RockDisposalAreaRose PitTailingsManagementFacilityProposed RailwayRose SouthWaste RockDisposalAreaLicensesFermontLABRADORFIGURE ID: ALD_ST_672QUÉBEC0 2 4KilometresCLIENT:CLIENTIssuesIssues arising during Aboriginal, public DRAWING and stakeholder NAME engagement included lossor contamination of fish habitat, the decline in fish populations or species, andcumulative effects on Fish, Fish Habitat and Fisheries. In order to address theseissues, Alderon is working with Fisheries and Oceans Canada (DFO) to developa compensation plan in compliance with the Fisheries Act. In addition, effluentand site drainage will be collected and treated as per regulatory requirements, toresult in an acceptable effluent quality prior to discharge. A complete record of allcomments with responses is included in Appendix B.DRAWING TITLE:43

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryFrequency of issues raised during engagement activitiesNumber of Times Issue was Raised14121086420123Fish Habitat Fish Population Cumulative Effects onFish and Fish HabitatPotential Environmental EffectsThe Project will interact with the Freshwater Fish, Fish Habitat and Fisheries wherethere is a change in fish habitat including: alteration or removal of existing fishhabitat; change in water quality or sediment quality; change in water flow rates;and potential barriers to fish passage.Effects on fish and fish habitat is anticipated during the construction phase of theProject, at the proposed open pit and associated waste rock disposal areas, and theTailings Management Facility. Waterbodies, including Waldorf River will be crossedby site access roads and/or the rail line. Effects to fish habitat will be limited toalterations and losses from site preparation and construction activities.2Fish health and mortality is not likely to be affected, with the potential minorexception of limited injury and loss associated with fish re-location prior todewatering ponds or streams. Fish health is not likely to experience a highmagnitude effect as habitat protection and effluent quality measures will minimizeadverse effects.There is no commercial fishing in the area and there are no reported Aboriginal orsubsistence fisheries in the area. The removal of fish habitat during constructionwill result in loss of opportunity for recreational fishing at the open pit site. Fishingoccurs at other locations in the Local Study Area and beyond.Mitigation MeasuresThe Fisheries Act is currently being amended to provide protection to ongoingAboriginal, commercial and recreational fisheries by protecting the productivity ofhabitat that supports them. The Act allows the Minister to issue an Authorizationunder Section 35 (2) which will permit the work, undertaking or activity to occurthat results in serious harm to fish. An Authorization will be issued only with theacceptance of an appropriate Compensation Plan which offsets any serious harm tofish, including permanent alteration or destruction of fish habitat. An Authorizationmust be issued before any action can be taken that would result in serious harm.The development and implementation of a Fish Compensation Plan will mitigatelosses of fish habitat resulting from the Project to avoid serious harm to fish.Other mitigation measures will include: control of total suspended solids throughsurface water management and settling ponds; treating mine site waters for44

contaminants as needed to meet regulatory standards; dust suppression; providingadequate surface water and baseline flows; correctly sizing and installing culverts;and minimizing riparian disturbance and progressively rehabilitating..Residual Environmental EffectsGiven the implementation of mitigation measures, the Project is not likely to resultin significant adverse environmental effects under normal operating conditions.7.2.6 Birds, Other Wildlife and TheirHabitats and Protected AreasBirds, Other Wildlife and Their Habitats and Protected Areas includes migratoryand non-migratory birds (such as waterfowl, raptors, shorebirds, wetland birdsand other land birds), amphibians, small mammals, ungulates (such as sedentaryor migratory caribou populations in the region, and moose), and furbearers (suchas black bear, wolf, marten, red fox, beaver and otter). Protected Areas are alsoconsidered as a component because of the potential for interactions betweenProject activities and existing or planned designated protected areas (such asnational, provincial and regional parks; protected natural areas and watersheds;ecological reserves), and the need to protect ecosystems, species diversity,important habitats, and ecosystems.Information used to determine the known or likely presence of wildlife species inor near the Project Development Area was derived from reviews of local historicalrecords and other baseline data sources including Species at Risk Act (SARA) andNewfoundland and Labrador Endangered Species Act registries, Committee on theStatus of Endangered Wildlife in Canada (COSEWIC) Status Reports, Recovery andManagement Plans (where available), government and non-government sources,existing literature and field data collection.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary45

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryHistoric records indicate that 163 bird species, of which 138 are consideredmigratory, have been observed in western Labrador Site-specific surveysrecorded 30 songbird species, 15 waterfowl species and five other bird species.Waterbirds were generally observed wherever suitable habitat was available. Fieldinvestigations confirmed the presence of several mammals in the Regional StudyArea. No caribou were observed, nor were any mammalian species of conservationconcern observed.Terrestrial wildlife in western Labrador ranges from large animals to furbearers andother small mammals. During wildlife surveys conducted for the Kami Project in2011 and 2012, no caribou was observed in the vicinity of the Project site. Mooseis a relatively new species to Labrador, having expanded its range into westernLabrador by dispersal from Québec in the 1950s. Black bear is the largest predatorfound in western Labrador. Furbearers in western Labrador include: wolf, red fox,eastern coyote, Canada lynx, marten, least weasel, ermine, wolverines, Americanmink, river otter, snowshoe hare, red squirrel and beavers. Other mammal speciesfound in western Labrador include porcupine and several small mammals includingred-backed vole, meadow vole, masked shrew and meadow jumping mouse.The main groups of birds in western Labrador include raptors, waterfowl, andforest songbirds. Other species of shorebirds, upland game birds (grouse andptarmigan species), water birds (gulls, terns, sandpipers), and woodpeckers arealso present. Western Labrador is part of the Atlantic Flyway (the eastern most ofseveral continent-wide corridors for migratory waterfowl). There are two groupsof migratory waterfowl associated with the timing of their arrival at breedinglocations in this region. The early-nesting group is comprised of dabbling ducksand geese and the late-nesting group is comprised of sea ducks and diving ducks.Waterfowl identified during surveys included Common Merganser, CommonGoldeneye, Canada Goose, American Black Duck, and Ring-necked Duck.Songbirds in western Labrador include members of the flycatcher, corvid, thrush,warbler, finch, and sparrow families. The most prevalent species were WhitethroatedSparrow, Ruby-crowned Kinglet, American Robin, Slate-coloured Juncoand Yellow-rumped Warbler. Two fauna species (birds) listed as species at riskwere observed in the vicinity of the Project site - Olive-sided Flycatcher andRusty Blackbird.There are four Protected Areas that are adjacent to or overlap with proposedinfrastructure for the Project: Duley Lake Provincial Park Reserve, Pike Lake SouthManagement Unit (management unit within the municipality of Labrador City),Jean Lake Rapids Management Unit and Elephant Head Management Unit (lattertwo are management units within Wabush).46

Birds, Other Wildlife and their Habitats and Protected Areas Local and Regional Study AreasRegional Study AreaLabrador City500Wabush MineProposedPowerlineDuley Lake Provincial(Nalcor)Park ReserveLocal Study AreaRose NorthWaste RockDisposalAreaRose PitTailingsManagementFacilityRose SouthWaste RockDisposalAreaLicensesFermont±Wabush MineWabushProposedAccess RoadProposed RailwayKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryLABRADORQUÉBECFIGURE ID: ALD_ST_6750 2 4KilometresIssuesCLIENTEffects on wildlife species was the key issue identified during consultation andDRAWING NAMEengagement activities. Potential effects to parks and protected areas, waterfowl,and wildlife habitat were also raised as concerns. A variety of Project design andmitigation measures are incorporated into the Project to control emissions anddischarges from the site, avoid sensitive species and their habitat to the extentpossible, implement an Avifauna Management Plan, and minimize the size of thedisturbed area. Alderon is in the process of persuing a Corporate StewardshipAgreement to address concerns related to the wetlands stewardship program. Acomplete record of all comments with responses is included in Appendix B.CLIENT:DRAWING TITLE:47

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryFrequency of issues raised during engagement activitiesNumber of Times Issue wasRaised252015105022Wildlife Species6 6Parks and ProtectedAreas4Waterfowl Wildlife habitat Cumulative Effects onWildlife SpeciesPotential Environmental EffectsActivities associated with Project construction, operation and maintenance,decommissioning and reclamation have the potential to affect the VEC. Sitepreparation and construction activities will result in the most importantadverse effects of the Project through a change in habitat (loss or alteration ofapproximately 22 km 2 of habitat for wildlife species), a change in distributionand movement (such as abundance and distribution of wildlife species, sensorydisturbance), a change in mortality risk (the direct loss of individual animals), achange in health (increased stress levels leading to the introduction of disease,and the masking of key auditory signals) and a change in protected areas (directloss of a portion of the Pike Lake South Management Area, a Wetland HabitatManagement Unit).The effects of operational maintenance activities include some noise-relatedeffects and site lighting which can lead to mortality of migrating birds under certainconditions (such as fog or mist at night).3Mitigation MeasuresEffects on birds, other wildlife and their habitat, and protected areas will bemitigated through a series of measures designed to limit the area disturbed by theProject and then to control the emissions and discharges. The primary mitigationmeasures for Project-related effects include a Corporate Stewardship Agreementthat Alderon is in the process of pursuing, an Avifauna Management Plan,restricting clearing to the period outside the breeding bird season (where feasible),no hunting or harassment of wildlife on Project site, and progressive reclamation.Residual Environmental EffectsGiven the implementation of mitigation measures, the Project is not likely to resultin significant adverse environmental effects under normal operating conditions.48

7.2.7 Species at Risk and Species of Conservation ConcernSpecies at risk and species of conservation concern include species of plant oranimal, and/or its critical habitat, that is of provincial, national or internationalimportance, particularly where the species and/or its critical habitat is affordedprotection under federal or provincial legislation. Species at risk is a species thatfederally listed under Schedule 1 of SARA as “Endangered” or “Threatened” orprovincially listed under Newfoundland and Labrador Endangered Species Act(NLESA) as “Endangered”, “Threatened” or “Vulnerable”. A species of conservationconcern is species ranked as extremely rare or rare throughout its range in theprovince by Atlantic Canada Conservation Data Centre for vegetation; and/orranked “May Be At Risk”, “Sensitive” or “Undetermined” by the NLDEC.The assessment for this VEC included background research, field studies, andeffects analysis focusing on species protected by the Species At Risk Act (SARA)and the Newfoundland and Labrador Endangered Species Act. The majority ofdata were collected through surveys completed during the 2011 and 2012 fieldseasons including detailed animal and vegetation surveys, wetland surveys andrare plant surveys.There were no observations of any plant species listed as species at risk withinthe Project Development Area. Eight plant species of conservation concern wererecorded in the Local Study Area including northern valerian, green false hellebore,chestnut sedge, lesser panicled sedge, whitestem pondweed, spike muhly, tallnorthern green orchid and yellow sedge. Occurrences of all these species werealso recorded outside the vicinity of the Project. Two bird species listed as speciesat risk were observed in the vicinity of the Project site - Olive-sided Flycatcher andRusty Blackbird. There were no observations of fish species at risk or fish species ofconservation concern.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary49

Frequency of issues raised during engagement activitiesNumber of Times Issue was Raised765432106Caribou1 1Cumulative Effects onSpecies at RiskSpecies at RiskPotential Environmental EffectsActivities associated with Project construction, operation and maintenance,decommissioning and reclamation have potential to affect the abundanceand distribution of rare or sensitive plant species. The Project will result in thealteration or loss of approximately 22 km 2 of habitat that will result in the loss ofsome habitat (less than five percent of the area within the RSA). Effects to plantspecies of conservation concern will be limited to the construction phase wheresurface disturbance activities occur. Of the eight plant species recorded within theLocal Study Area, all were recorded elsewhere in the Regional Study Areas. Thepreferred habitat types for Olive-sided Flycatcher are generally well representedin the greater landscape, accounting for approximately 21 percent of the RegionalStudy Area. Habitat for Rusty Blackbird is common in the Regional Study Area.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryMitigation MeasuresWhere feasible, plant species of conservation concern will be avoided. Whereavoidance is not possible, transplantation of plant species of conservation concernto alternate sites will be investigated. A number of mitigation measures will beimplemented to minimize environmental effects including minimizing of the Projectfootprint, establishing buffer around wetlands and riparian areas, and avoidingknown locations of rare species or species of conservation concern, to the extentfeasible.Residual Environmental EffectsGiven the implementation of mitigation measures, the Project is not likely to resultin significant adverse environmental effects under normal operating conditions.51

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary7.2.8 Historic and Cultural ResourcesHistoric and Cultural Resources include sites, materials, landscapes or places ofhistoric, archaeological, cultural / spiritual, palaeontological, and architecturalimportance. Background research, field surveys, archaeological potential mapping,and informant interviews were all completed to characterize baseline conditionsand support the assessment of the potential effects of the Project.Results of the background investigation indicated there was no known potential forcultural or spiritual sites, common fossil-types, or architectural resources to occurwithin the Project Development Area or in areas adjacent to it.Historic and Cultural Resources Local and Regional Study AreasRegional Study AreaLabrador CityFermontScheffervilleTshiuetinRailway!!!^_!Wabush!Emeril Junction!Ross Bay JunctionTwin Falls±S m a l l w o o dR e s e r v o i rChurchill Falls! !KamiMine SiteLabrador CityKamiMine SiteWabushQuebec North Shoreand Labrador RailwayFermont^_Local StudyAreaLicenses^_ !Sept ÎlesTerminal SiteFIGURE ID : ALD_ST_6760 20 40Kilometres52

IssuesIssues identified during consultation and engagement activities that relate tohistoric and cultural resources are disturbance of archaeological sites and potentialeffects on burial sites. A complete record of all comments with responses isincluded in Appendix B. Although archaeological sites have not been found and arenot likely to be found, mitigation measures will be implemented in the event of anunexpected discovery of historic and cultural resources.Frequency of issues raised during engagement activitiesNumber of Times Issue was Raised65432105Disturbance of Archaeological Sites1Potential Effects on Burial SitesPotential Environmental EffectsA review of the Newfoundland and Labrador Archaeological Site Record Inventoryindicated that no archaeological or contemporary sites are registered within theLocal Study Area. Site-specific field surveys conducted within the Local Study Areaalso did not identify any sites. All Project activities that could potentially resultin disturbance or loss of historic and cultural resources were assessed. However,because there are no archaeological sites within the local study area, the Projectwill not affect, or physically disturb, any known sites of archaeological importance.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryMitigation MeasuresAlthough archaeological sites have not been found and are not likely to be found,mitigation measures will be implemented in the event of an unexpected discoveryof historic and cultural resources, consistent with Alderon’s EnvironmentalProtection Plan.Residual Environmental EffectsThe Project is not likely to result in significant adverse environmental effects undernormal operating conditions.53

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary7.2.9 Current Use of Lands and Resources forTraditional Purposes by Aboriginal PersonsThe Guidelines require Alderon to assess the effect of any change that the Projectmay cause on the current use of land and resources for traditional purposesby Aboriginal persons. The current use of land and resources for traditionalpurposes by Aboriginal persons is a VEC because it is part of the CEAA definition ofenvironmental effect. In order to assess the effects of the Project upon the currentuse of land and resources for traditional purposes by Aboriginal persons, the EIS:• Identifies lands, waters and resources of specific social, economic,archaeological, cultural or spiritual value to Aboriginal persons; and• Describes the current use of those lands, waters and resourcesfor traditional purposes -- fishing, hunting, trapping, plantharvesting and navigation and other similar activities conductedfor food, social, cultural or ceremonial purposes.Alderon has conducted the assessment of the Project effects on the VEC byoverlaying the proposed Project components and activities with availableinformation respecting the nature, geographic range and frequency of currentAboriginal land and resource use activities in order to identify potentialinteractions.Currently, no Aboriginal group has a settled land claim which includes the Projectarea. However, there are five Aboriginal groups which have asserted Aboriginalrights and title in and to the lands of western Labrador, including the Project Area,and which claim this region as their traditional territory:• Labrador Innu;• NunatuKavut Community Council (NCC);• Uashat Mak Mani-Utenam Innu (Québec);• Matimekush - Lac John Innu (Québec); and the• Naskapi Nation of Kawawachikamach (Québec)The Project also overlaps two beaver conservation reserves purportedly createdby the Québec government in 1954 (Lots 244 and 245 of the Saguenay BeaverReserve). While Lots 244 and 245 of the Saguenay Beaver Reserve are locatedentirely within Labrador and are therefore not subject to Québec legislation, theseareas are the subject of asserted interests by certain traditional families of Uashatmak Mani-Utenam.Alderon has reviewed all available information respecting land and resourceuse, including information provided directly by Aboriginal groups during theengagement process. In addition, Alderon has also reviewed information producedby land and resource use studies prepared by Aboriginal groups either as part ofthe Project environmental assessment or for the environmental assessment ofother projects in western Labrador and northeastern Québec.54

Current Use of Land and Resources for Traditional Purposes by Aboriginal Persons Local andRegional Study Areas±Regional Study AreaKawawachikamachTshiuetinRailwayLabrador CityFermontKamiMine SiteU n g a v a B a y^_Matimekush - Lac JohnWabushSmallwood ReservoirFermontLocal Study AreaKamiMine SiteNatuashish!(Labrador City^_Sheshatshiu!(WabushLicensesA T L A N T I CO C E A NKami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary!( !( !(!(Terminal Site^_Uashat Mak Mani-UtenamG u l f o f S t . L a w r e n c eQuebec North Shoreand Labrador Railway!( Labrador Innu!(Québec Innu andNaskapi CommunitiesFIGURE ID : ALD_ST_6770 50 100KilometresIssuesIn order to determine the potential effects of the Project upon current Aboriginalland and resource use for traditional purposes, Alderon has made significant effortsto engage with each of the five identified Aboriginal groups to understand landand resource use activities in the region and to identify and respond to communityconcerns associated with the potential effects of the Project upon these activities.Issues raised by Aboriginal groups include possible interaction of the Project withexisting Aboriginal rights or title; and possible impact on traditional land andresource use activities. Alderon recognizes that the Project area is contained withinlands subject to asserted Aboriginal right and will continue to engage Aboriginalgroups and communities in order to monitor the effects of the Project uponAboriginal land and resource use.A complete record of all comments with responses is included in Appendix B.55

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryFrequency of issues raised during engagement activitiesNumber of Times Issue was Raised252015105021Interaction with ExistingAboriginal Rights or Title18Traditional Land UseActivities by AboriginalPotential Environmental EffectsAlderon has assessed the effects of the Project upon this VEC from threeperspectives —activity distribution, activity levels and quality and cultural valueof the activity—and has concluded that the Project is not likely to result in anysignificant adverse effects to the current use of lands and resources for traditionalpurposes by Aboriginal persons.Existing and available information indicates that none of the five Aboriginal groupscurrently undertakes traditional land and resource use activities within or nearthe PDA or the LSA. Current land and resource use by the Labrador Innu appearsto be focused in central and southeastern Labrador and while there is evidenceof some usage in western Labrador along the TransLabrador Highway, this activitydoes not appear to occur within or near the Project area. While each of Uashatmak Mani-Utenam and Matimekush-Lac John engage in land and resource use fortraditional purposes within their traditional territories, the activities are conductedin areas in proximity to the communities and not within the PDA or the LSA. Inaddition, there is no evidence that trapping or any other land and resource useactivity is currently practiced by Uashat mak Mani-Utenam in Lots 244 and 245 ofthe Saguenay Beaver Reserves. Similarly, the Naskapi Nation of Kawawachikamachhas indicated in its engagement with Alderon that it does not enter the PDA andthat its land and resource use activities are concentrated in the areas surroundingKawawachikamach and other areas that are accessible by railway and road.NCC members residing in Labrador City and Wabush currently undertake a varietyof land and resource use activities throughout the region, including hunting,fishing, berry picking, camping and associated travel. However, such activities,while clearly reflective of local knowledge, may not be considered traditionalin that they are not necessarily a continuation of ancestral activities that werepracticed by this group historically within this area of Western Labrador. Theactivities of NCC members have however been considered integrally within theoverall assessment of current land and resource use in and near the Project area.The Project will result in localized effects within the PDA and LSA. Such effectsinclude restrictions upon site access within the PDA for security reasons during56

construction and operations, alteration of the natural landscape and other localizeddisturbances in the PDA and LSA due to noise, dust and visual intrusions. However,these localized effects and disturbances will not adversely affect the location orfrequency of current land and resource use by Aboriginal persons for traditionalpurposes. While the Project area is within the asserted traditional territory ofeach of the five Aboriginal groups, there is no evidence of current use of land andresources for traditional purposes by any of the groups within either the PDA or theLSA. Nor are there any known sites of historical, cultural or spiritual importance toany Aboriginal group within either the PDA or the LSA. Any current use of land andresources for traditional purposes by Aboriginal persons in the region outside theLocal Study Area will be unaffected as the Project will not result in any significantadverse effects upon the quantity or quality of vegetation, fish or wildlife resourcesor upon habitat. As a result and based on information available to Alderon, theProject is not likely to adversely affect the location or availability/timing of thecurrent use of land and resources for traditional purposes by Aboriginal persons.Alderon has also assessed the effects of Project-employment upon the ability ofAboriginal persons to participate in traditional land and resource use activities inthe RDA. Although there is no evidence of traditional land and resource usage ineither the PDA or in the LSA, traditional activity levels in the region may be affectedby increased participation in the Project workforce. Employment for extendedperiods away from home communities may interfere with traditional activities andother cultural pursuits. To address these potential effects, Alderon will continue toengage with each Aboriginal group to consider alternative work rotations and/orcultural leave provisions to permit participation in traditional activities.As the Project is not likely to adversely affect the location or timing of the currentuse of land and resources for traditional purposes by Aboriginal persons, nor theoverall level of participation in such activities by Aboriginal persons and groups,no associated and consequent decrease in the overall quality or underlyingcultural value of the current use of land and resources for traditional purposes byAboriginal persons is anticipated.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryMitigation MeasuresAlthough based on information obtained to date there is no evidence that theProject will have significant adverse effects upon the current use of land andresources for traditional purposes by Aboriginal persons, Alderon recognizes thatthe Project area is contained within lands subject to asserted Aboriginal rights.Alderon will continue to engage Aboriginal groups and communities in order tomonitor the effects of the Project upon Aboriginal land and resource use and willtake such mitigation measures as may be necessary and appropriate.Residual Environmental EffectsThe Project is not likely to result in significant adverse environmental effects undernormal operating conditions.57

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary7.2.10 Other Current Use of Lands and ResourcesOther Current Use of Lands and Resources is defined as any current (1990 topresent) land use or harvesting, including industrial uses, undertaken by non-Aboriginal persons or communities in western Labrador and Fermont, Québec. Inparticular, this VEC focuses on current use of lands and resources in the Local StudyArea and Regional Study Area. The assessment of Project environmental effects onthis VEC included a review of publically available secondary source material anddetailed informant interviews with local land and resource users to characterizelocal and regional baseline conditions.Baseline data collection and analysis indicates that many people from LabradorCity, Wabush, and Fermont, use the lands and resources of western Labrador fora number of recreational activities such as snowmobiling, fishing and resourceharvesting. There are many cabins located in western Labrador, the majority ofwhich are situated along the major water bodies such as Long Lake, Walsh River,Mills Lake, Waldorf River, Riordan Lake, and Upper and Lower Loon lakes.58

Other Current Use of Lands and Resources Local and Regional Study AreasTshiuetinRailway!!!^_KamiMine SiteFermont!Labrador CityWabushFermontLocal Study AreaLabrador City^_ScheffervilleWabushLicensesSmallwoodRegional Study AreaChurchill FallsReservoir!Nain!Natuashish!Hopedale!SheshatshiuHappy Valley-Goose BayA T L A N T I C!O C E A N!±!Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryCartwrightCharlotKamiMine SiteQuebec North Shoreand Labrador RailwayFIGURE ID : ALD_ST_6800 20 40KilometresIssuesIssues raised during consultation include potential effects on cabins, recreationalactivities, potential effects on snowmobile trails, land use activities, fishingactivities, hunting activities, access to property, property value, trapping, woodharvesting, and travel routes. Alderon will comply with all applicable regulatorystandards and will develop mitigation/effects management measures andmonitoring to be implemented at the appropriate Project phase to minimize effectson land use. Alderon will continue to engage with cabin owners to address Projecteffects. Changes to visual aesthetics, including red water and large Project features,were identified as an issue by many participants. Alderon conducted a viewshedanalysis and developed before and after photosimulations. These analyses indicatethat large Project features will be minimally visible from the three adjacentmunicipalities. A complete record of all comments with responses is included inAppendix B.59

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryFrequency of issues raised during engagement activitiesNumber of Times Issue was Raised4540353025201510503919118 7 6 5 5 41 1 1Potential Environmental EffectsSeveral Project activities will require implementation of restricted access zonesaround Project activities and features, and/or alteration of landscapes orwaterbodies alteration. These restrictions and alterations will affect access to landsand resources during Project construction and operation and maintenance phasesand result in a corresponding change in level of activity or use of these lands andresources. Change in cabin use could result from elevated noise and dust levelsand/or by change in access to cabin areas. The current viewscape may be alteredby physical features or works that are visible from outside the Project DevelopmentArea. The Project was also assessed for effects to designated land use.Mitigation MeasuresMitigation measures to minimize adverse effects involve a combination ofdesign features (such as use of span bridges to facilitate navigation, progressiverehabilitation, relocation of Project features to minimize viewshed effects)and effects management measures (such as air/noise/water management,development of a blasting plan). Alderon is also committed to continuedengagement with stakeholder groups to understand and address potential issuesof concerns. More specifically, Alderon will work with local snowmobile and crosscountry ski organizations to address Project effects, and with cabin owners toaddress Project effects on access.Residual Environmental EffectsGiven the implementation of mitigation measures, the Project is not likely to resultin significant adverse environmental effects under normal operating conditions.60

7.2.11 Community Services and InfrastructureCommunity Services and Infrastructure was selected as a VEC because the Projecthas the potential to affect the ability of nearby communities, Labrador City,Wabush and Fermont to deliver physical and social services and infrastructure.Baseline data on demographics and information about services and infrastructurewas collected through organization websites, interviews with municipalgovernments and local and regional authorities and boards and agencies at thecommunity level.Background information for Community Services and Infrastructure includeda description of the current situation and recent trends in western Labradorand Fermont with respect to employment and social services, health servicesand social programs, training and education services and programs, safety andsecurity, municipal administrative capacity, municipal services and infrastructure,recreational services and infrastructure, availability of services and infrastructurefor women, transportation infrastructure, commercial and industrial infrastructureand housing and accommodations (residential and tourist).Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary61

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryCommunity Services and Infrastructure Regional Study AreaRegional Study AreaLabrador City500Local Study AreaWabush MineProposedPowerlineDuley Lake Provincial(Nalcor)Park ReserveRose NorthWaste RockDisposalAreaRose PitTailingsManagementFacilityRose SouthWaste RockDisposalAreaLicensesFermontWabush MineWabushProposedAccess RoadProposed Railway±LABRADORQUÉBECFIGURE ID: ALD_ST_6710 2 4KilometresCLIENT:IssuesCLIENTPotential issues of concern relating to DRAWING Community NAME Services and InfrastructureDRAWING TITLE:include availability of housing for workers, community infrastructure, communityservices, increased road traffic, temporary construction camp, recreationalinfrastructure, cumulative effects, increased railway traffic, light, health services,and increased air travel. Alderon will implement a number of managementinitiatives to minimize Project effects including engagement with town councilsto develop a Project accommodation plan, and building an access road to theProject site to minimize Project-related traffic on municipal roads. Alderon hasalso been participating in the Labrador West Regional Task Force and the LabradorWest Community Advisory Panel to address issues related to community servicesand infrastructure in western Labrador. A complete record of all comments withresponses is included in Appendix B.62

Frequency of issues raised during engagement activitiesNumber of Times Issue was Raised5045403530252015105046Availability ofHousing forWorkers26CommunityInfrastructure22CommunityServices21IncreasedRoad Traffic20TemporaryConstructionCamp14RecreationalInfrastructure9CumulativeEffect onCommunityServices andInfrastructure7 7IncreasedRailway TrafficLight5 5HealthServicesIncreased AirTravelPotential Environmental EffectsEffects on Community Services and Infrastructure will primarily be a function ofthe level of in-migration to the area and the consequent increase of demand oninfrastructure and services. Potential effects between the Project and municipalservices and infrastructure in western Labrador during construction will beassociated primarily with the:• Movement of personnel and some material andequipment through the Wabush Airport;• Movement of personnel, materials and equipmentby road through western Labrador;• Increased demands on services and infrastructurearising from Project-related in-migration.Potential effects between the Project and community services and infrastructureduring operation will be associated primarily with in-migration. Due to theirproximity and infrastructure, Labrador City and Wabush will be the primary hub forthe Project, through which non-local labour will arrive and depart, and materialsand equipment will be shipped. Therefore, most of the Project effects on servicesand infrastructure are expected to occur there. These effects are not expectedto be significant as a result of regular liaison between Alderon and relevantauthorities.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryMitigation MeasuresTo manage effects related to affordable and available housing, Alderon is currentlynegotiating MOUs with the Town of Labrador City and the Town of Wabush todevelop and implement a Project accommodation strategy. Alderon will have anumber of management initiatives in place to minimize Project effects during allphases including building an access road to the Project site to minimize Projectrelatedtraffic on roads. Alderon will continue to evaluate potential Project-relatedimplications of the use of local, regional and provincial infrastructure and services.This will include direct Project requirements as well as indirect and inducedincreases in use of and demand for infrastructure and services by Project workersand their families.Residual Environmental EffectsGiven the implementation of mitigation measures, the Project is not likely to resultin significant adverse environmental effects under normal operating conditions.63

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary7.2.12 Health and Community HealthHealth and Community Health considers both individuals and communities thatmay be affected (beneficially and/or adversely) by various Project components andactivities and/or their associated and resulting environmental outcomes (e.g., dust,noise, light and/or aesthetic changes; presence of Project works and personnel,employment and income). Various indicators, including self-assessed health status,and prevalence of disease, are used to analyze community health in westernLabrador. Overall, the residents of western Labrador enjoy relatively high levels ofgood health and well-being and report lower levels of life stress compared to otherjurisdictions. A Human Health Risk Assessment was conducted for the Project toassess effects to physical effects.Health and Community Health Local and Regional Study AreasRegional Study AreaTrans Labrador Highwayand Other RoadsScheffervilleTshiuetinRailwayLabrador CityKamiMine Site^_FermontTerminal SiteWabushLocal Study AreaChurchill FallsS m a l l w o o d R e s e r v o i rTwin FallsEmeril JunctionRoss Bay JunctionQuebec North Shoreand Labrador RailwaySept Îles^_ ! G u l f o f S t . L a w r e n c eFIGURE ID : ALD_ST_6970 20 40Kilometres±64

IssuesIssues identified during consultation and engagement activities that relate tohealth and community health are shown in the figure below. The main issues raisedby participants include quality of life, visual aesthetics, human health, safety, andcumulative effects. A complete record of all comments with responses is includedin Appendix B. Alderon will develop mitigation/effects management measures andmonitoring to manage effects on Health and Community Health.Frequency of issues raised during engagement activitiesNumber of Times Issue was Raised35302520151050332921Quality of Life Visual Aesthetics Human Health Safety Cumulative Effectson Health andCommunity HealthPotential Environmental EffectsPhysical health is primarily affected by air emissions and water discharges, andalthough effects on air and water quality will begin during construction, theyare expected to be greatest during operations, diminishing again at closureand post-closure. The operation and maintenance of the Project will result infugitive emissions of chemicals of potential concern; however, based on thecurrent planned mitigation these emissions will not result in any exceedancesof the air quality standards at the representative receptor locations, except fora slight exceedance of PM 2.5at the southern end of Long Lake. This phase of theProject will also result in fugitive dust emissions, however, based on the currentplanned mitigation these emissions will not result in any measurable change inbaseline soil quality at the representative receptor locations nor will the predicteddust fall result in any measurable accumulation of metals in vegetation at therepresentative receptor locations.119Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryDuring the operation and maintenance phase, potential adverse effects to surfacewater resources include changes to drainage patterns, changes to flow regimes,water and sediment quality.The Project will result in employment opportunities and associated incomebenefits which will have an overall beneficial effect on the quality of life in westernLabrador.Increased drug and alcohol abuse and criminal activity may at times be associatedwith major development projects, and the region has been seeing increases inthese and other issues in recent years.65

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryMitigation MeasuresAlderon will implement mitigation measures related to avoiding or reducing effectson atmospheric environment, water resources, vegetation, soils, viewscapes andother relevant biophysical and socioeconomic VECs. These measures will mitigatepotential effects on both physical health and community health.Alderon will offer a comprehensive Employee Assistance Program to providesupport to workers, and will comply with the relevant provisions of any concludedbenefits agreement respecting workplace policies and conditions.Residual Environmental EffectsGiven the implementation of mitigation measures, the Project is not likely to resultin significant adverse environmental effects under normal operating conditions.7.2.13 Economy, Employment and BusinessEconomy, Employment and Business was chosen as a VEC because the Project’sinfluence on the economy, on employment, and on business is fundamentalto assessing socio-economic implications for the lives of local residents and ofrevenues to governments. Baseline research was based on geographic data regionsused by Statistics Canada and the Newfoundland and Labrador Statistics Agency.The main information sources included Statistics Canada, the Newfoundland andLabrador Statistics Agency and its Community Accounts website, provincial andmunicipal governments, training institutions, regional economic developmentboards, and other public agencies. Using these information sources, the baselineconditions were characterized for existing employment and income conditions,skilled and unskilled labour supply, employment equity and diversity including66

potentially under-represented groups, income levels, sources of income, businessand industry profile, tourism related activities and business capacity.Economy, Employment and Business Regional Study AreasTshiuetinRailwayLabrador CityFermont! !! ^_!ScheffervilleWabushLocal Study AreaSmallwoodChurchill FallsRegional Study Area!ReservoirNain!Natuashish!HopedaleSheshatshiu!Happy Valley-Goose Bay!!Rigolet!A T L A N T I CO C E A NCartwright!Charlottetown!±Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryKamiMine SiteQuebec North Shoreand Labrador RailwayFIGURE ID : ALD_ST_6820 40 80KilometresIssuesPotential issues ^_ of concern related to Economy, Employment and Business includeAboriginal employment and business opportunities, availability of local workers,local economy, apprenticeship and training, diversity in the workplace, potentialeffects on local businesses, cumulative effects, financial benefit for municipality,and business access. Alderon will address these issues in the Project Benefits Planand Diversity Plan. A complete record of all comments with responses is included inAppendix B.67

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryFrequency of issues raised during engagement activitiesNumber of Times Issue was Raised353025201510503222 22 22Potential Environmental EffectsThe Project will affect Economy, Employment and Business through expenditureson supplies and services and employment. The direct, indirect and induced effectsof Project spending, together with business taxes, royalties and grants in lieu,will also contribute to municipal and Newfoundland and Labrador revenues. Anindependent economic assessment estimates that the Project will contribute $26billion to the provincial GDP. During construction and operations, the Project willresult in 39,810 person-years of direct, indirect and induced employment, of which17,916 will occur in western Labrador. The Project will also result in $2.7 billion indirect, indirect, and induced incomes to workers and local businesses. The Projectwill generate $4.3 billion in tax revenues to Newfoundland and Labrador and $3.5billion to the federal government.18131021Mitigation MeasuresThe majority of effects management for Project-related effects related to changesin economy, employment and business will be established in the Project BenefitsPlan and Diversity Plan. They will contain effects management initiatives andrelated outcome targets that will be subject to negotiation with the Government ofNewfoundland and Labrador.Residual Environmental EffectsGiven the implementation of mitigation/effects management measures, the Projectis not likely to result in significant adverse environmental effects under normaloperating conditions. The overall residual effects of the Project on Economy,Employment and Business are predicted to be positive, given the nature of theProject and the use of effects management approaches and measures describedAlderon’s Project Benefits Plan and Diversity Plan. Economy, Employment andBusiness represent the primary means by which the Project will deliver benefits toadjacent communities and to the region and province within which it is located.68

7.3 Effects of the Environment on the Project7.3.1 Method and ApproachThe Local Study Area for the purpose of assessing the effects of the environmenton the Project is the watershed areas that are upstream of the Project features(mine, mill, waste disposal areas, conveyors, roads, and rail). This was selectedas the study area for most of the environmental factors because water (watersupply, flooding, and ice) will have the greatest potential effect on the Project asdetermined within the distinct subwatersheds. Other environmental factors such asclimate and geology (including seismicity) are described for a larger area becausethe effects are transient (such as weather) or more widely felt (such as seismicity).The effects of these events on the Project were assessed.7.3.2 IssuesNo comments or issues related to effects of the environment on the Project wereraised during Alderon’s engagement activities. A complete record of all commentswith responses is included in Appendix B.7.3.3 Potential Environmental EffectsEffects of the environment on the Project considers how local conditions andnatural hazards, such as severe and/or extreme weather conditions and externalevents (flooding, ice jams, rock slides, landslides, fire, outflow conditions andseismic events) could adversely affect the Project and how this in turn couldaffect the environment (such as environmental emergencies due to extremeenvironmental conditions).Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryEnvironmentalConditionTemperaturePrecipitationLong TermClimate ChangeSeismicityPotential Effects• Deep frost ground penetration.• Ice depths can constrain the intake and discharge depth / location ofwater supply and effluent discharge lines as well as the orientationof intake screens and effluent diffusers. The location and depth ofwater supply and discharge lines will be designed to avoid ice.• Long and extensive precipitation storage as snow duringwinter requiring snow clearing / plowing capacity.• Long and extensive snowpack accumulation in the TMF may tie upsurface water availability for reclaim purposes. Long Lake will be used asa source for processing water when reclaim water supply is limited.• Snowfall accumulations can be large due to little wintersnow ablation and minimal sublimation and therefore theProject will account for large structural snow loads.• Extreme rain events could result in flooding• Potential effects of climate change on operation of the Projectwould be primarily related to increases in the frequency ofadverse weather events and changes in precipitation.• Increases in extreme weather events could potentially affect operation ofthe Project by increasing unscheduled maintenance due to storm damage.• The mine and process plant water supply will be extracted fromnearby Long Lake, decreases in the local precipitation and water table,if they occur, could adversely affect the Project’s water supply.• Geological hazards and disasters including landslides, avalanches,rockfalls, and coastal flooding as a result of seismic activity offshore.69

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary7.3.4 Mitigation MeasuresThe primary mitigation is sound planning. All engineering design will adhere tonational and international standards. These standards document the properengineering design for site-specific normal and extreme physical environmentalconditions and provide design criteria that the regulatory agencies considersatisfactory for withstanding the potential physical environmental conditions.Building codes consider physical environmental criteria such as temperature,wind, snow, and ice loading, and drainage. In addition, the design life is taken intoconsideration so that materials are chosen with sufficient durability and corrosionresistance.7.3.5 Residual Environmental EffectsPlanning and design of the Project has and will continue to consider extremeclimatic, hydrologic, and geohazard criteria. Experience of other iron ore minesin the area, in combination with prescribed codes and standards, provides a highlevel of confidence that environmental conditions are not likely to significantlyaffect the Project. Site monitoring will be undertaken to identify potential problemsand verify effective mitigations. As such, no significant adverse effects of theenvironment on the Project are anticipated.7.4 Effects of Possible Accidents or Malfunctions7.4.1 Method and ApproachThe potential environmental effects of each potential Accident and Malfunctionwas assessed for each VEC, based on the existing conditions of each VEC andexisting knowledge about the environmental effects of the accidental events.Four accidental event scenarios have been assessed for the Project including trainderailment, forest fire, dyke breach, and premature shutdown.7.4.2 IssuesThroughout its consultation and engagement process, Alderon has listened toquestions and concerns expressed by Aboriginal groups, stakeholders and thepublic. Alderon has heard from several individuals who have expressed concernabout the rail line that will pass through the water supply for the town of Wabush,and the potential for a train derailment that could result in adverse environmentaleffects to their water supply. Other concerns expressed about accidental eventsincluded the discharge of untreated effluent into Duley (Long) Lake and systemsto inform resident of Fermont, Québec, in the event of an accident at the Projectsite. Alderon will develop an Emergency Response Plan prior to the initiation of theconstruction phase. A complete record of all comments with responses is includedin Appendix B.70

7.4.3 Potential Environmental EffectsPotential accidents and malfunctions that may occur as a result of Project activitiesare identified and assessed for the five reasonable worst case scenarios.Train DerailmentFuel will be transported along the rail line to the Project site and ore concentratewill be transported from the Project site to the QNS&L railway. There is potential,in the event of a train derailment, that fuel and/or iron ore concentrate couldbe deposited along and adjacent to the rail line right-of-way. The rail networkserving Labrador has a good safety record and the performance suggests that thelikelihood of a rail spill of fuel or derailment fuel is low.Forest FireAlthough unlikely, Project activities involving the use of heat or flame couldresult in a fire. The extent and duration of a resulting fire would be dependent onresponse efforts and meteorological conditions. A Fire Suppression Water Supplywill be extracted from Long Lake and will be kept pressurized at the pumpingstation near the concentrator area. Staff will be trained to prevent and controlfires. A plan for preventing and combating forest fires will be incorporated into theEmergency Response Plan.Dyke BreachThere is potential of a breach at the polishing pond dyke which may releaseeffluent into the downstream environment. To mitigate the potential accidentalevent or malfunction from occurring, the dykes located at the Tailings ManagementFacility will be designed to standards of the Canadian Dam Association (CDA) DamSafety Guidelines. The CDA Dam Safety Guidelines will be used to guide the hazardconsequence assessment process and associated design standards for the dykes atthe Tailings Management Facility.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryPremature or Permanent ShutdownIt is currently planned that the mine will be operational until approximately theend of 2033, at which time closure and rehabilitation will commence. However,should market conditions change or other factors arise that result in the prematureshutdown of the mine, regulatory requirements include provision for financialassurance from Alderon. All events associated with activities included in theDevelopment Plan, the Rehabilitation and Closure Plan, as well as those activitiesrequired for ongoing site monitoring and maintenance are included in financialassurance coverage.7.4.4 Mitigation MeasuresIn the unlikely event of any of these scenarios, adverse environmental effectscould result. An Emergency Response Plan will be developed prior to initiation ofconstruction activities and will include detailed measures for responding to theaccidents and malfunctions listed above. With the exception of a forest fire, itis not expected that the assessed accidents and malfunctions would affect bothjurisdictions because the effects of a spill would be contained within the affectedwatershed, and would not migrate from Labrador to Québec. In the event ofa forest fire that could affect both jurisdictions, Alderon will notify all relevantagencies; however, there is low likelihood of a Project-related forest fire occurring.71

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary7.4.5 Residual EffectsAccidents and malfunctions by definition have a very low likelihood of occurring,and accordingly the environmental effects of accidents and malfunctions, includingthose that would be significant if they were to occur, have a low likelihood ofoccurring.7.5 Effects on Capacity of Renewable ResourcesA required component of a comprehensive study is to “address the capacity ofrenewable resources that are likely to be significantly affected by the project tomeet the needs of the resent and the future”. Renewable resources that may beaffected by the Project are:• Water resources;• Wetlands;• Fish and fish habitat;• Waterfowl and other wildlife.With consideration in Project design and implementation of mitigation measures,there are no likely significant adverse effects, and as a result, adverse Projecteffects on the capacity of renewable resources to meet the needs of the presentand those of the future are not anticipated.7.6 Cumulative Environmental Effects7.6.1 ApproachThe overall effect on each VEC as a result of the Project’s residual environmentaleffects in combination with the environmental effects of other relevant projectsand activities that have been or will be carried out was assessed. Cumulativeenvironmental effects were assessed in the Regional Study Area specific to eachVEC (i.e., the spatial boundaries in which cumulative environmental effects arepredicted to occur), and the assessment focuses on the degree of change frombaseline VEC conditions resulting from the Project acting in combination with otherrelevant on-going and future projects.7.6.2 ScopingOn-going and reasonably foreseeable future projects with environmental effectsthat are likely to overlap in space and time with those of the Project include:• Labrador Operations (existing and planned expansions) – Iron Ore Company(IOC) of Canada;• Wabush Mines - Cliffs Resources;• Mont Wright Mine - ArcelorMittal;• Bloom Lake Mine and Rail Spur - Cliffs Resources;• Schefferville Iron Ore Mine - Labrador Iron Mines;• DSO Iron Ore Project - Tata Steel (formerly New Millennium);• Lower Churchill Generation Project;• Infrastructure or other projects at the Port of Sept-Iles.72

7.6.3 IssuesIssues identified during consultation and engagement activities that relate tocumulative effects are shown in the figure below. The issues raised most frequentlyby participants include cumulative effects to Economy, Employment and Business,cumulative effects to Community Services and Infrastructure, and cumulativeeffects to Health and Community Health. Issues identified during consultationand engagement activities that relate to cumulative effects are presented inAppendix B. Alderon is participating in the Labrador West Regional Task Force tomanage effects collaboratively with local mining companies, municipalities andgovernments. The mitigation and effects management measures proposed byAlderon will mitigate the overall cumulative effect of the Project in combinationwith other projects and activities.Frequency of issues raised during engagement activitiesNumber of Times Issue was Raised12108642109 9543 32 21Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary073

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary7.6.4 Potential Cumulative EffectsOn-going and reasonably foreseeable future projects that are likely to overlap inspace and time with those of the Kami Project are identified in the table below as a“Y” to represent a cumulative effect on the VEC.Name of Project/ActivityLabrador Operations(existing and plannedexpansions) – Iron OreCompany of CanadaWabush Mines - CliffsResourcesMont Wright Mine -ArcelorMitalBloom Lake Mineand Rail Spur - CliffsResourcesSchefferville Iron OreMine - Labrador IronMinesDSO Iron Ore Project- Tata Steel (formerlyNew Millennium)Lower ChurchillHydroelectricGeneration ProjectInfrastructure or otherprojects at the Port ofSept-ÎlesAtmospheric EnvironmentLandforms, Soils, Snow and IceWater ResourcesWetlandsFreshwater Fish, Fish Habitatand Mortality and FisheriesBirds, Other Wildlife and TheirHabitats, and Protected AreasSpecies at Risk and Species ofConservation ConcernHistoric and Cultural ResourcesCurrent Use of Lands and Resources forTraditional Purposes by Aboriginal PersonsY Y N Y Y Y Y N Y Y Y Y YY Y N Y Y Y Y N Y Y Y Y YN Y N N N Y Y N Y Y Y N NY Y N Y N Y Y N Y Y Y N NN N N N N Y Y N Y N Y N YN N N N N Y Y N Y N Y N YN N N N N Y N N Y N N N YN N N N N Y N N Y N N N NUrbanization N Y N Y Y Y Y N Y Y N N NOther Current Use of Lands and ResourcesCommunity Services and InfrastructureHealth and Community HealthEconomy, Employment and Business74

7.6.5 Mitigation MeasuresThe mitigation and effects management measures proposed by Alderon willmitigate the overall cumulative effect of the Project in combination with otherprojects and activities. In addition, Alderon is participating in the LabradorWest Regional Task Force and the Labrador West Community Advisory Panel tomanage effects collaboratively with local mining companies, municipalities andgovernments. The groups serve to identify ways in which multiple stakeholdersmay collaborate to manage impacts upon the communities of Labrador City andWabush arising from the rapid growth of the local mining industry.7.6.6 Residual EffectsThe cumulative effects of other projects and activities with the Kami Mine Projectwere deemed not significant. Current and future activities are subject to regulatoryapproval processes and standard mitigation measures which would limit adverseeffects. The Project has the potential to cumulatively interact with past, presentor future projects, resulting in cumulative effects to: Atmospheric Environment;Landforms, Soils, Snow and Ice; Wetlands; Freshwater Fish, Fish Habitat, andFisheries; Birds, Other Wildlife and Their Habitats, and Protected Areas; Speciesat Risk and Species of Conservation Concern; Current Use of Lands and Resourcesfor Traditional Purposes by Aboriginal Persons; Other Current Use of Lands andResources; Community Services and Infrastructure; Health and Community Health;and Economy, Employment and Business. However, given the mitigation proposedfor this Project which will prevent or minimize adverse environmental effects,cumulative effects are predicted to be not significant for all VECs.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary75

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary8.0 FOLLOW-UP PROGRAMA follow-up and monitoring program will be designed and conducted, asappropriate, during all phases of the Project.The purpose of the follow-up program is to verify the accuracy of the predictionsmade in the environmental assessment as well as the effectiveness of themitigation measures. Follow-up programs are proposed in those cases where thereis uncertainty effects prediction due to the nature of the effect (i.e., unique orrelatively unknown) or lack of information. Follow-up program results will be usedto refine and optimize mitigation measures and implement adaptive managementmeasures associated with the Project.The proposed follow-up and monitoring programs are summarized below.VECAtmosphericEnvironmentLandforms,Soils, Snow andIceWaterResourcesWetlandsCommitment• Ambient air monitoring at the facility boundaryand within the nearest communities• Annual monitoring of GHG emissions and reporting to Environment Canada• Sound pressure level monitoring during both construction and operation• Monitoring cut and fill locations have been placed, as wellas any stream crossings for drainage conditions• Personnel will supervise soil stripping, stockpiling, and replacement operations• Volumes of stockpiled soil will be measured andtracked from salvage to replacement• Soil stockpiles will be monitored to ensure erosion control and revegetationmeasures are effective and proper signage is in place• Vegetation growth and erosion will be monitored onreplaced soils against reclamation standards• Regular checks of snow fences will be completed from November to Aprilto ensure that fences are properly placed and functioning properly• Monitor runoff from stockpiles, discharge from TMF, and mine waterfrom the pit for pH, TDS, sulfate, and dissolved metals, as per MMERand the NL Environmental Control Water and Sewage Regulations• Surface water quantity monitoring during construction, operations and closure• Surface water quality monitoring during construction, operations and closure• Establishment of water quantity withdrawal / discharge thresholds• Establishment of water balance restoration targets• Erosion / sedimentation monitoring• Restoration of drainage patterns at closure• Monitoring of channel and water feature naturalization• Monitoring of OPM filling• Install permanent monitoring wells at OPM, TMF and select mine facilities• Monitoring of groundwater chemistry and water levels• Perimeter and off-site water level monitoring (OPM,TMF, site)• OPM sump discharge monitoring• Water quality monitoring (TMF, OPM Inflows)• Emergency response for spills• Post decommissioning monitoring of water levels near Rose Pit• Post decommissioning monitoring of groundwater chemistry near TMF• Compliance monitoring will be conducted to confirm that wetlandmitigation measures are appropriately implemented76

VECFish, FishHabitat andFisheriesBirds, OtherWildlife andTheir Habitats,and ProtectedAreasSpecies at Riskand Species ofConservationConcernHistoric andCulturalResourcesCurrent Useof Lands andResources byAboriginalPersons forTraditionalPurposesOther CurrentUse of Landsand ResourcesCommunityServices andInfrastructureHealth andCommunityHealthEconomy,Employmentand BusinessCommitment• Monitoring compliance with Compensation Plan• Water quality and biota sampling as per MMER requirements• Compliance monitoring will be conducted to confirm thatmitigation measures are appropriately implemented• Monitor for compliance with mitigation measures• Variety of monitoring and education initiatives• Compliance monitoring will be conducted to confirm thatmitigation measures are appropriately implemented• Compliance monitoring will be conducted to confirm thatmitigation measures are appropriately implemented• On-going engagement with Aboriginal communities and organizations• Continue engagement with local resource user groups such asthe local snowmobile club and cross country ski club• On-going engagement with cabin owners• On-going liaison with municipalities• Engagement with local authorities and provide updateson Project activities and plans on a regular basis• Alderon will, as appropriate, support and participate in theformation of a joint monitoring initiative which would includethe towns of Wabush, Labrador City and Fermont• Engage with the relevant agencies and organizations, particularly theLabrador West Regional Task Force and the Labrador West CommunityAdvisory Panel, to provide Project information and to identify anddiscuss potential Project-related implications for local services andinfrastructure, including those of Project-related in-migration• Continue to work with local and regional communities and agenciesand service providers to identify and plan for any associated issues,including through the provision of up-to-date project information andschedules. This will include its continued participation in the Labrador WestCommunity Advisory Panel, and the Labrador West Regional Task Force.• Monitor and Report on Project Benefits and Diversity Planperformance, such as success in meeting targets, as detailed inthe Benefits Agreement, Benefits Plan and Diversity Plan• Support and participate in the formation of a jointmonitoring initiative which would include the towns ofWabush, Labrador City and Fermont, as appropriateKami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary77

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary9.0 BENEFITS OF THE EA TO CANADIANSIn addition to meeting regulatory requirements, this environmental assessmentprocess has resulted in various benefits to Canadians. This includes maximizedenvironmental benefits, supporting sustainable development, public participation,increases in scientific knowledge and community and social benefits. Examples ofhow the environmental assessment process for this Project benefits Canadians ispresented below.Factors of EA ProcessProviding Benefitsto CanadiansMaximizedEnvironmentalBenefitsSupportingSustainableDevelopmentPublic ParticipationIncreases in ScientificKnowledgeCommunity and SocialBenefitsCommitment• The Project access route was changed, and a new road isto be constructed in order to eliminate the potential fortraffic congestion along Grenfell Drive in Wabush.• The Rose South Waste Rock Disposal Area was originally planned to belocated adjacent to the pit and closer to the town of Fermont, Québec.In response to public requests and their concerns over potentialenvironmental effects to the town and its residents, Alderon hasrelocated the waste rock disposal area approximately 5 km to the east.• The TMF was sited to avoid waterbodies, to the extent possible.• Through an environmental constraints analysis conducted at an earlystage in the EA process, Project components were located to avoid,where economically and technically feasible, environmentally sensitiveareas such as lakes and the Duley Lake Provincial Park Reserve. As such,environmental effects on these features were minimized by avoidance.• Use of non-conventional technologies is not requiredto minimize environmental effects.• The Project is being designed and will be constructedand operated in consideration of progressiverehabilitation and future closure and reclamation.• Public input has influenced the design of the Project inseveral major ways. As noted above, the Project access routewas changed to avoid Grenfell Drive in Wabush as a resultof public concern over increased traffic congestion.• Project planning in response to public input will also result indecreased nuisance and improved visual aesthetics for residents ofthe town of Fermont as a result of relocating the waste rock disposalarea several kilometres to the east and away from the town.• The understanding of the existing environment within andsurrounding the Project area has been greatly improved as aresult of baseline studies conducted in support of the EA.• A Benefits Plan and a Diversity Plan have been developed aspart of the EA process so that Project benefits are optimized.78

10.0 OVERALL CONCLUSIONS OF THEPROPONENTThe Kami Mine Project has been designed and will be undertaken to mitigateadverse environmental effects to acceptable levels.Concerns that have raised by Aboriginal groups and the public, and therequirements prescribed in the EIS Guidelines have been addressed by assessingthe environmental effects that will or may result from the construction, operationand maintenance, and decommissioning and reclamation of the Project.The Kami Projectwill result in positiveeffects to the localand provincialeconomy, employmentand business.In summary, the Project will not resultin likely adverse residual significanteffects, in isolation or cumulatively withother projects and activities. Accidentsand malfunctions, should they occur,may result in significant effects forsome VECs; however these are notlikely to occur given the planningthat has been undertaken, and thestandards that have been prescribed.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary79

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary11.0 REFERENCESEnvironment Canada. 2012. Canadian Climate Normals 1971 - 2000, Wabush LakeA, Newfoundland. Available at: http://www.climate.weatheroffice.gc.ca/climate_normals/index_1961_1990_e.html. Accessed: April 2012.Government of Newfoundland and Labrador. 2011. A Minerals Strategy forNewfoundland and Labrador. Discussion Paper. http://www.nr.gov.nl.ca/nr/mineralstrategy/minerals_strategy.pdfNalcor Energy. 2009. Lower Churchill Hydroelectric Generation Project.Environmental Impact Statement. Volume 1 Part A – Regional EnvironmentalSetting and Context.Protected Areas Association of Newfoundland and Labrador (PAANL). 2008. L5Mid Subarctic Forest. Newfoundland and Labrador Ecoregion Brochures Project.Available at: http://www.env.gov.nl.ca/env/publications/parks/index.html.Statistics Canada. 2012. 2011 Census of Canada (Community Profiles). StatisticsCanada, Ottawa, ON. Available at: http://www12.statcan.gc.ca/censusrecensement/2011/dp-pd/prof/index.cfm?Lang=E.Accessed: April 2012.Wilkin, E.B. 1986. Terrestrial Ecozones of Canada. Ecological Land Classification,Series No.19. Environment Canada. Hull, PQ.80

Appendix AVEC Summary Tables and Residual EffectsSummary MatricesKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 81

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary(this page is deliberately blank, for layout purposes)A – 82

Table A.1Summary of Project Residual Environmental Effects: Atmospheric EnvironmentProject PhaseChange in Air QualityConstructionOperation andMaintenanceDecommissioningand ReclamationChange in GHG EmissionsConstructionOperation andMaintenanceDecommissioningand ReclamationChange in Acoustic EnvironmentConstructionOperation andMaintenanceDecommissioningand ReclamationMitigation / Compensation Measures• Fugitive dust suppression programs.• Equipment preventativemaintenance programs.• Dust control for the crusher buildingsand all conveyor transfer points.• Covered Conveyors, as required.• Use qualified blasting contractorswith blast design plans thatincorporate dust emission controls.• Progressive reclamation on thewaste rock piles and TMF.• Limit on-site speed to 50 km/h.• Equipment idling policy.• Equipment preventativemaintenance programs.• Implementation of a GHGManagement Plan.• Use of mufflers onconstruction equipment.• Adherence to equipmentmaintenance programs.• Maintain a vegetation bufferbetween the Project and nearbyresidents and cabins.• Limit train speed to 50 km/h or less.Change in VibrationsConstruction • Adherence to equipmentOperation andMaintenanceDecommissioningand Reclamationmaintenance programs.• Limit train speed to 50 km/h or less.• Use of continuous welledtrack and ballast system.DirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA M L ST R R D N HA M L MT C R D N HA M L ST R R D N HA M G ST R R D N HA M G MT C R D N HA M G ST R R D N HA M L ST R R D N HA M L MT C R D N HA M L ST R R D N HRecommended Follow‐upand Monitoring• Ambient air qualitymonitoring.• Annual monitoring of GHGemissions and reportingto Environment Canada.• Sound pressure levelmonitoring during bothconstruction and operation.AAALMLLLLSTMTSTSSSRRRDDDNNNHHH• Vibration monitoring willbe conducted along railroute located nearest thecabins and in residentialareas as appropriate.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 83

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryProject PhaseChange in Light EmissionsConstructionOperation andMaintenanceDecommissioningand ReclamationKey:Mitigation / Compensation Measures• Direct light where needed.• Retain a vegetation screen,where possible.• Locate portable lightingequipment where not visible insurrounding urban areas.• Use of full horizontal cut offlight fixtures, as appropriate.Direction:P Adverse: condition of the atmosphericresources is worsening in comparisonto baseline conditions and trends.P Positive: condition of the atmosphericresources is improving in comparisonto baseline conditions and trends.N Neutral: no change in the condition ofthe atmospheric resources comparedto baseline conditions and trends.Magnitude:N Negligible: no measurable adverseeffect anticipated.L Low: effect occurs that is detectablebut is within normal variability ofbaseline conditions.M Moderate: effect occurs that wouldcause an increase with regard tobaseline but is within regulatory limitsand objectives.H High: effect occurs that would singlyor as a substantial contribution incombination with other sourcescause exceedances of objectivesor standards beyond the Projectboundaries.DirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA L L ST S R D N HA L L MT R R D N HA L L ST S R D N HGeographic Extent:S Site-specific: effect restricted to theProject footprint within the LSA.L Local: effect restricted to the LSA.R Regional: effect restricted to the RSA.G Global: Provincial, National or Globalscale (GHG Emissions only).Duration:ST Short-term: effect occurs for less thantwo years.MT Medium-term: effect occurs forbetween 2 and 15 years.LT Long-term: effect persists beyond 15years.P Permanent: will not change back tooriginal condition .Frequency:O Once: effect occurs once.S Sporadic: effect occurs at sporadicintervals.R Regular: effect occurs on a regularCbasis and at regular intervals.Frequently: effect occurs continuouslythroughout the Project life.Recommended Follow‐upand MonitoringReversibility:R Reversible: effect ceases when Projectoperations cease.o Irreversible: effect continues afterProject operations cease.Environmental or Socio-economic Context:U Undisturbed: effect takes placewithin an area that is relatively or notadversely affected by human activity.D Developed: effect takes place withinan area with human activity. Areahas been substantially previouslydisturbed by human development orhuman development is still present.Significance:S Significant.N Not Significant.Prediction Confidence:Based on scientific information andstatistical analysis, professional judgmentand effectiveness of mitigation or effectsmanagement measureL Low level of confidence.M Moderate level of confidence.H High level of confidence.A – 84

Table A.2Summary of Project Residual Environmental Effects:Landforms, Soils, Snow and Ice, and ARD / MLProject PhaseMitigation / Compensation MeasuresChange in Landforms and Terrain StabilityConstruction • Minimize use of esker materialfor aggregate use.Operation and • Maintain existing drainageMaintenance to the extent possible.Decommissioningand ReclamationChange in Soil Quality and QuantityConstruction • Manage the collection andstorage of soil stockpiles.• Promote the vegetation of soilstockpiles to prevent erosion.Operation and • Design surface drainage to preventMaintenance flooding of stockpile areas.• Erosion control protocolswill be followed.Decommissioning • Volumes of soil stored in stockpilesand Reclamation will be measured and trackedfrom salvage to replacement.• Progressive rehabilitation.• Fugitive dust suppression programsChange in Ice and SnowConstructionOperation andMaintenanceDecommissioningand ReclamationARD/ML• Design facilities and activitiesto minimize dust emissions.• Use of snow fences and snow removal.• Implementation of speed limits.• Manage blasting so that the vibrationswill not affect ice cover at nearby lakes.DirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA L-H S M S I N/A N HA L S S S I N/A N HN L S P O I N/A N HA L L MT R R N/A N HA L L MT O R N/A N HN L L MT R R N/A N HA M L ST R R N/A N MA M L ST R R N/A N MA L L M R I N/A N HRecommended Follow‐upand Monitoring• Monitor for compliancewith mitigation measures.• Monitor for compliancewith mitigation measures.• Monitor for compliancewith mitigation measures.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryConstructionOperation andMaintenanceDecommissioningand Reclamation• Effluent discharge will be treated tomeet MMER discharge criteria.N N L ST C I U N MN N L ST C I U N MN N L ST C I U N M• Monitor for compliancewith mitigation measures.A – 85

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryKey:Direction:P Positive.A Adverse.N Neutral.Magnitude:N NegligibleL Low: for landforms, minor changesto shape and stability from a regionalperspective; for soils, changes of lessthan or equal to 5 percent.M Moderate: for landforms, moderatechanges to shape and stability from aregional perspective; for soils, changesof 5 to 10 percent.H High: for landforms, a major changeto shape and stability in the regionalarea; for soils, changes of greater than10 percent.Geographic Extent:S Site: effect confined to the PDA and200 m beyond.L Local: effect confined to the LSA.R Regional: effect extends beyond theLSA but within the RSA.Duration:STShort-term: effects last through theconstruction phase.MT Medium-term: effects last beyond theconstruction phase, but not beyondthe end of Project decommissioning.LTPLong-term: effects are measureablefor up to 30 years beyond the life ofthe Project.Permanent – effects will not changeback to original condition.Frequency:O Once: effect occurs once.S Sporadic: effect occurs occasionallybut not consistently throughout thelife of the Project.RCRegular: effect occurs at regularintervals throughout the life of theProject.Continuous: effect occurs continuouslythroughout the Project.Reversibility:RIReversible: environment will likelyrecover to baseline conditions afterthe end of Project decommissioning.Irreversible: environment is unlikelyto recover to baseline conditionsafter the end of the Projectdecommissioning..Environmental or Socio-economic Context:U Undisturbed: area relatively or notadversely affected by human activity.D Developed: area has beensubstantially previously disturbedby human development or humandevelopment is still present.N/A Not Applicable.Significance:S Significant.N Not Significant.Prediction Confidence:Based on scientific information andstatistical analysis, professional judgmentand effectiveness of mitigation or effectsmanagement measureL Low level of confidence.M Moderate level of confidence.H High level of confidence.A – 86

Table A.3Summary of Project Residual Environmental Effects: Water ResourcesProject PhaseChange in Surface Water QuantityConstructionOperation andMaintenanceDecommissioningand ReclamationChange in Surface Water QualityConstructionOperation andMaintenanceDecommissioningand ReclamationMitigation / Compensation Measures• Implement progressive rehabilitation.• Optimize water harvesting and re-use .• Restore existing water balanceconditions, to the extent feasible.• Refer to Table 16.52 fordetailed mitigation list.• Implement erosion andsedimentation controls.• Use of appropriately sizedsedimentation ditches and ponds.• Ammonia contamination management.• Implement effluent treatment, includingred water control as per optionsoutlined in the Project Description.• Restore natural drainage patternsand maintain or restore existingwater balance condition,to the extent feasible.• Manage effluent treatment to meetMMER and NL ECWSR discharge limits.• Refer to Table 16.52 fordetailed mitigation list.Change in Surface Water Drainage PatternsConstructionOperation andMaintenanceDecommissioningand Reclamation• Minimize drainage interactionsand alterations.• Construct open pit mineheadwater pipeline.• Construct open pit mine and wasterock disposal area perimeter ditches.• Construct access roads andrail line cross drainage.• Restore natural drainage patternsand maintain or restore existingwater balance conditions,to the extent feasible.• Refer to Table 16.52 fordetailed mitigation list.DirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceRecommended Follow‐upand MonitoringA L S ST R R U N H • Surface water quantityA L L MT R R U N H(water level) monitoringduring construction,P L S ST O R U N Hoperations and closure.A L S ST S R U N HA L L MT R R U N HA L S ST S R U N HA L S ST R R U N HA L S MT R R U N HP L S ST S R U N H• Surface water qualitymonitoring duringconstruction, operationsand closure.• Compliance monitoringof mitigation.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 87

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryProject PhaseMitigation / Compensation MeasuresDirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextChange in Groundwater Quality or QuantityConstruction • Best management practices.• Blast monitoring. A L S ST S R U N HOperation andMaintenanceDecommissioningand ReclamationKey:• Implement best managementpractices.• Refer to proposed monitoring.• Open pit mine flooding.Direction:P Positive: condition of Water Resourcesis improving in comparison to baselineconditions and trends.A Adverse: condition of Water Resourcesis declining in comparison to baselineconditions and trends.N Neutral: no change in the conditionof Water Resources compared tobaseline conditions and trends.Magnitude:N Negligible: no measurable effectanticipated.L Low: effect occurs that is detectablebut is within normal variability ofbaseline conditions.M Moderate: effect occurs that wouldcause an increase with regard tobaseline but is within regulatory limitsand objectives.H High: effect occurs that would singlyor as a substantial contribution incombination with other sourcescause exceedances or objectives orstandards within the Project RSA.Geographic Extent:S Site-specific: effect restricted to theProject footprint within the LSA.L Local: effect restricted to the LSA.R Regional: effect restricted to the RSA.Duration:STSignificancePrediction ConfidenceA L L MT R R U N HP L S ST O R U N HShort-term: effect occurs for less thantwo years.MT Medium-term: effect occurs forbetween three and 20 years.LT Long-term: effect persists beyond 20years.PPermanent: will not change back tooriginal condition.Frequency:O Occasionally: effect occurs once permonth or less.S Sporadic: effect occurs sporadically atirregular intervals.R Rarely: effect occurs on a regular basisand at regular intervals.C Continuous: effect occurs continuouslythroughout the Project life.Reversibility:R Reversible: effect ceases when Projectoperations cease.I Irreversible: effect continues afterProject operations cease.Recommended Follow‐upand Monitoring• Groundwater monitoringwells to monitor waterlevels, flows and chemistry.Ecological or Socio-economic Context:U Undisturbed: effect takes placewithin an area that is relatively or notadversely affected by human activity.D Developed: effect takes place withinan area with human activity. Areahas been substantially previouslydisturbed by human development orhuman development is still present.N/A Not Applicable.Significance:S Significant.N Not Significant.Prediction Confidence:Based on scientific information andstatistical analysis, professional judgmentand effectiveness of mitigation or effectsmanagement measureL Low level of confidence.M Moderate level of confidence.H High level of confidence.A – 88

Table A.4Summary of Project Residual Environmental Effects: WetlandsProject PhaseMitigation / Compensation MeasuresChange in Wetland Quality and QuantityConstruction • Minimize wetland loss and restrictconstruction activities to the PDA.• Comply with provincial andfederal legislation, permits,approvals and guidelines.• Maintain hydrology at stream crossings.• Maintain natural drainage,where possible.• Erosion and sediment control.• Invasive species management.• Progressive reclamation,including wetland restoration.• Corporate Stewardship Agreement.Operation and • Comply with provincial andMaintenance federal legislation, permits,approvals and guidelines.• Erosion and sediment control.• Invasive species management.• Progressive reclamation,including wetland restoration.Decommissioningand Reclamation• Wetland Stewardship Agreement.• Comply with provincial andfederal legislation, permits,approvals and guidelines.• Erosion and sediment control.• Invasive species management.DirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA M S LT O I U/D N HA L S LT C I D N HA/P M S LT O I D N HRecommended Follow‐upand Monitoring• Monitor implementationof mitigation measures.• Monitor implementationof mitigation measures.• Monitor implementationof mitigation measures.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 89

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryKey:Direction:P Positive.A Adverse.N Neutral.Magnitude:L Low: the residual Project effects towetlands (alteration/loss) are notexpected to exceed 5 percent of thetotal area of wetland in the RSA.M Moderate: the residual Project effectsto wetlands (alteration/loss) areexpected to be greater than 5 percentand not exceed 25 percent of the totalarea of wetland in the RSA.H High: the residual Project effectsto wetlands (alteration/loss) areexpected to exceed 25 percent of thetotal area of wetland in the RSA. Effectcan be easily observed, measured anddescribed, and may be widespread.Geographic Extent:S Site-specific: Effect confined to thefootprint for all Project features(i.e., PDA). Effects limited to directlyaffected wetlands.L Local: Effect extends beyond theProject footprint into the surroundingareas (LSA), including potentiallyaffected wetland communities within1 km of the mineral license.R Regional: Effect extends into the RSA.Area where indirect or cumulativeeffects may occur.B Effect extends beyond the regionalstudy area. Area where indirect orcumulative effects may occur.Duration:STShort-term Effect occurs during thesite-preparation or construction phaseof the Project (i.e., 1 to 2 years).MT Medium-term Effect extendsthroughout the construction andoperation phases of the Project (up to17 years.LT Long-term Effect is greater than 17years.P Permanent Effect persists.Frequency:OSROnce Effect occurs occasionally, oronce during the life of the Project(e.g., clearing).Sporadic Effect occurs sporadically,at irregular intervals, without anypredictable pattern during the life ofthe Project (e.g., hydrocarbon spills).Regular Effect occurs on a regular basisand at regular intervals during the lifeof the Project.C Continuous Effect occurs continuously.Reversibility:R Reversible Effect is reversible duringthe life of the Project.I Irreversible A long-term effect that ispermanent (i.e., remains indefinite asa residual effect).Environmental or Socio-economic Context:U Undisturbed: Area relatively or notadversely affected by human activity.D Developed: Area has beensubstantially previously disturbedby human development or humandevelopment is still present.N/A Not Applicable.Significance:S Significant.N Not Significant.Prediction Confidence:L Low level of confidence.M Moderate level of confidence.H High level of confidence.A – 90

Table A.5Summary of Project Residual Environmental Effects:Freshwater Fish, Fish Habitat, and FisheriesProject PhaseMitigation / Compensation MeasuresDirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextChange in Fish HabitatConstruction • Compensation Plan as requiredunder Fisheries Act Authorization. N L S P C I U N HOperation andMaintenanceDecommissioningand Reclamation• N/AFish Health or MortalityConstructionOperation andMaintenanceDecommissioningand Reclamation• Any activities near/within waterbodieswill most likely require review underthe Fisheries Act at that time.SignificancePrediction ConfidenceN/A N/A N/A N/A N/A N/A N/A N HN/A N/A N/A N/A N/A N/A N/A N H• Fish relocation.• Maintenance of flows. A N S T O R U N M• Fish screens.• Blasting guidelines.• MMER regulations regarding discharges.• Any activities near/within waterbodieswill most likely require review underthe Fisheries Act at that time.Change in Utilization of Existing FisheriesConstruction • Compensation Plan as requiredunder Fisheries Act Authorization.Operation and • N/AMaintenanceDecommissioning • N/Aand ReclamationN N L T C R D N MN/A N/A N/A N/A N/A N/A N/A N HA N L L C I U N HN/A N/A N/A N/A N/A N/A N/A N HN/A N/A N/A N/A N/A N/A N/A N HRecommended Follow‐upand Monitoring• Fish habitat compensationmonitoring underFisheries Act.• Water quality samplingas per EPP/EEMrequirements.• Water quality andbiota sampling as perMMER requirements.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 91

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryKey:Direction:P Positive: condition is improvingcompared to baseline.N Neutral: no change compared tobaseline.A Adverse: negative change compared tobaseline.Magnitude:N Negligible: no measureable adverseeffects anticipated.L Low: measureable effects anticipatedin low-sensitivity habitats and nomeasureable reduction in the numberof fish species anticipated.M Moderate: measureable effectsanticipated in moderately sensitivehabitat or anticipated mortality risk tonon-listed species.H High: measureable effects anticipatedin highly sensitive habitat or habitatdesignated as important to listedspecies or anticipated mortality risk tolisted species.Geographic Extent:S Site Specific: effects restricted to PDA.L Local: effects extend beyond the PDAbut remain within the LSA.R Regional: effects extend to the RSA.Duration:T Temporary: effects are measureablefor days to a few months.M Moderate: effects are measureable forup to a year but not multiple years.L Long-term: effects are measurable formultiple years but not permanent.P Permanent – effects arepermanent.Frequency:O Once: effect occurs only one time.S Sporadic: effect occurs more thanonce at irregular intervals.R Regular: effect occurs on a regularbasis and at regular intervals.C Continuous: effect occurs constantly.Reversibility:R Reversible: effect will cease during orafter the Project is completeI Irreversible: effects will persist afterthe life of the Project, even afterhabitat restoration and compensationworksEnvironmental Context:U Undisturbed: effect takes place in anarea that has not been previouslyaffected by human development.D Developed: effect takes place inan area that has been previouslyaffected by human developed, in anarea where human development isstill present, or in an area previouslydisturbed by Project activities.Significance:S Significant:• A permanent and irreversible reductionin the productive capacity of fishhabitat that remains after mitigationand compensation measures areimplemented and which will likely resultin an uncompensated HADD of fishhabitat.• The likelihood of fish mortality, aftermitigation measures are implemented,at a level that would require regulatorybodies to implement specificmanagement plans for the recovery ofthe affected fish populations.• A significant measureable decrease infish condition, below baseline conditionsand directly attributable to Projectactivities, and which threatens thesustainability of the regional fisheries.• The Project is not compatible withrecreational fishing activities, such thatpatterns of fishing are changes acrossthe area.N Not Significant.Prediction Confidence:Based on scientific information andstatistical analysis, and effectiveness ofmitigation or effects management measureL Low: biological processes not wellunderstood, limited baseline data,predictive analysis not available,quantitative metrics limited, andmitigation measure effectivenessunknown.M Moderate: general biologicalprocesses understood, adequatebaseline, some predictive analysis,quantitative metrics available, provenmitigation measures.H High: biological process wellunderstood and predictable,adequate baseline and regional data,statistical and predictive modeling isproven, mitigation measures provensuccessful.A – 92

Table A.6Summary of Project Residual Environmental Effects:Birds, Other Wildlife and their Habitat; and Protected AreasProject PhaseChange in HabitatConstruction,Operation andMaintenanceMitigation / Compensation Measures• Minimize construction footprint(i.e., PDA) to the extent feasible;• Avoid sensitive species and theirhabitats to the extent feasible;• Minimize disturbance and infillingwithin adjacent wetlands andmaintain hydrological conditionsto the extent feasible;• Rehabilitate access routes thatare no longer needed;• Locate borrow pits more than 100m away from the high water markof water bodies, where feasible;• Maintain natural buffers aroundwetlands and riparian zones;• Dispose of slash from clearing,as specified in permits;• Comply with provincial andfederal legislation, permits,approvals and guidelines;• Implement erosion andsediment control;• Conduct invasive species management;• Conduct progressive rehabilitation; and• Implement an AvifaunaManagement Plan.• Invasive species management.• Progressive reclamation.DirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA L S LT O I U/D N HRecommended Follow‐upand Monitoring• Monitor for compliancewith mitigation measures.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 93

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryProject PhaseMitigation / Compensation MeasuresChange in Distribution and MovementConstruction, • Implement an AvifaunaOperations and Management Plan;Maintenance, • Minimize construction footprintDecommissioning (i.e., PDA) to the extent feasible.and Reclamation Avoid those locations of sensitivespecies to the extent feasible;• Restrict clearing activities to theperiod outside of the bird breedingbird season, whenever feasible;• Restrict clearing and other activitieswithin 800 m of an active raptor nest,and within 200 m of an inactive nest;• Flag the boundaries of sensitiveareas before commencingany work in the area;• Limit noise levels whenever feasible;• Allow wildlife to pass throughconstruction sites without harassment;• Comply with all provincial andfederal legislation, permits,approvals and guidelines;• Maintain hydrology at streamcrossings through approvedmethods to install culverts;• Implement erosion andsediment control;• Conduct invasive speciesmanagement; and• Conduct progressive rehabilitationChange in Mortality RiskConstruction• Prohibit hunting or harassmentof wildlife on Project site;• Implement Avifauna ManagementPlan to address incidental take;• Limit situations leading topotential collisions;• Use welding mats from April 1 toNovember 15 to prevent forest fires;• Dispose of all waste appropriately;• Limit lighting to that requiredfor safe operation;• Shield exterior lights from above; and• Use motion sensors for security lightingDirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA L S LT O I U/D N HA L S ST O R U/D N H • None.Recommended Follow‐upand Monitoring• Monitor for complianceof mitigation measures.A – 94

Project PhaseOperation andMaintenanceDecommissioningand ReclamationChange in HealthConstructionMitigation / Compensation Measures• Prohibit hunting or harassmentof wildlife on Project site;• Implement Avifauna ManagementPlan to address incidental take;• Limit situations leading topotential collisions;• Use welding mats from April 1 toNovember 15 to prevent forest fires;• Dispose of all waste appropriately;• Limit lighting to that requiredfor safe operation;• Shield exterior lights from above; and• Use motion sensors for security lighting• Prohibit hunting or harassmentof wildlife on the Project site.• Limit situations leading topotential collisions.• Consider clearing by mulching andmechanized forestry equipment;• Use best practices for fuels and otherhazardous materials, e.g., herbicides;• Implement various dustcontrolmeasures;• Do not bury waste during progressiverehabilitation activities;• Allow fuel trucks to travel onlyon approved access roads;• Ensure equipment arrives onsite free from fluid leaks;• Inspect and maintain equipmenton a regular schedule; and• Establish a site for equipmentmaintenance, repair and cleaningthat is at least 100 m from anylake, river, stream or wetlandDirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA L S ST O R U/D N H • None.A L S ST O R U/D N H • None.A L S ST R I U/D N H • None.Recommended Follow‐upand MonitoringKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 95

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryProject PhaseOperation andMaintenanceDecommissioningand ReclamationChange in Protected AreasConstructionOperation andMaintenanceDecommissioningand ReclamationMitigation / Compensation Measures• Consider clearing by mulching andmechanized forestry equipment;• Use best practices for fuels and otherhazardous materials, e.g., herbicides;• Implement various dustcontrolmeasures;• Do not bury waste during progressiverehabilitation activities;• Allow fuel trucks to travel onlyon approved access roads;• Ensure equipment arrives onsite free from fluid leaks;• Inspect and maintain equipmenton a regular schedule; and• Establish a site for equipmentmaintenance, repair and cleaningthat is at least 100 m from anylake, river, stream or wetland.• Use best practices for fuels and otherhazardous materials such as herbicides.• Implement various dustcontrol measures.• Measures listed for other potentialProject effects will be employed;• Establish a replacement protectedarea that performs the regionalprotection functions of the Pike LakeSouth Management area; and• Establish a CorporateStewardship Agreement.• Measures listed for other potentialProject effects will be employed;• Establish a replacement protectedarea that performs the regionalprotection functions of the Pike LakeSouth Management area; and• Establish a CorporateStewardship Agreement.• Employ measures listed for otherpotential Project effects.DirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA L S ST R I U/D N H • None.A L S ST R I U/D N H • None.A L L LT C I U/D N HA L L LT C I U/D N HA L L LT C I U/D N HRecommended Follow‐upand Monitoring• Variety of monitoring andeducation initiatives.• Variety of monitoring andeducation initiatives.• Variety of monitoring andeducation initiatives.A – 96

Key:Direction:P PositiveA AdverseN NeutralMagnitude:L Low - the residual Project effects(alteration/loss) are not expectedto exceed 5 percent of the knownpopulation in the RSA, and are notmeasureable.M Moderate - the residual Project effects(alteration/loss) are expected to begreater than 5 percent and not exceed25 percent of the known populationin the RSA and the effect can bemeasured.H High - the residual Project effectsto (alteration/loss) are expected toexceed 25 percent of the knownpopulation in the RSA; the effect canbe easily observed, measured anddescribed, and may be widespread.Geographic Extent:S Site-specific Effect confined to theProject footprint for all Projectcomponents (i.e., PDA), and limitedto directly affected environmentalcomponents.L Local: Effect extends beyond theProject footprint into the surroundingareas within the LSAR Regional: Effect extends beyond theLSA into the RSA, where indirect orcumulative effects may occur.B Beyond Regional: (provincial, national,and/or international extent) - Effectextends beyond the RSA, whereindirect or cumulative effects mayoccur.Duration:STShort-term Effect occurs during thesite‐preparation or construction phaseof the Project (i.e., 1 to 2 years).MT Medium-term Effect extendsthroughout the construction andoperation phases of the Project (up to17 years).LT Long-term Effect is greater than 17yearsP Permanent – Effect persists.Frequency:O Once - Effect occurs once during the lifeof the Project (e.g., clearing).SSporadic Effect occurs sporadically,at irregular intervals, without anypredictable pattern during the life ofthe Project (e.g., hydrocarbon spills).R Regular Effect occurs at regularintervals during the life of the ProjectC Continuous.Reversibility:R Reversible Effect is reversible duringthe life of the Project.I Irreversible A long-term effect that ispermanent (i.e., remains indefinitelyas a residual effect).Environmental or Socio-economic Context:U Undisturbed: Area relatively or notadversely affected by human activity.D Developed: Area has beensubstantially previously disturbedby human development or humandevelopment is still present.N/A Not Applicable.Significance:S Significant.N Not Significant.Prediction Confidence:L Low level of confidence.M Moderate level of confidence.H High level of confidence.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 97

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryTable A.7Summary of Project Residual Environmental Effects: SAR/SOCCProject PhaseChange in HabitatConstructionOperation andMaintenanceMitigation / Compensation Measures• Project design minimizesconstruction footprint (i.e.,PDA) to the extent feasible.• Delineate locations where plantSAR / SOCC occur, and avoid thoselocations to the extent feasible.• Minimize disturbance and infillingwithin adjacent wetlands andmaintain hydrological conditionsto the extent feasible.• Rehabilitate access routes thatare no longer needed.• Locate borrow pits more than 100m away from the high water markof water bodies, where feasible.• Maintain natural buffers aroundwetlands and riparian zones.• Dispose of slash from clearingas specified in permits.• Comply with provincial andfederal legislation, permits,approvals and guidelines.• Maintain hydrology at stream crossings.• Employ erosion and sediment control.• Implement progressive reclamation.• Restrict constructionactivities to the PDA.• Comply with all provincial andfederal legislation, permits,approvals and guidelines.• Implement erosion andsediment control.• Invasive species management.• Implement progressive reclamation.DirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA M S LT O I U/D N HA L S LT O I U/D N HRecommended Follow‐upand Monitoring• Monitor for compliancewith mitigation measures.• Monitor for compliancewith mitigation measuresA – 98

Project PhaseMitigation / Compensation MeasuresChange in Distribution and MovementConstruction and • Project design minimizesOperations and construction footprint (i.e.,Maintenance and PDA) to the extent feasible.Decommissioning • Flag the boundaries of sensitiveand Reclamation areas before commencingany work in the area.• Survey blasting areas for SAR or SOCCprior to any blasting activities.• Limit noise levels whenever feasible.• Allow wildlife to pass throughconstruction sites without harassment.• Comply with provincial andfederal legislation, permits,approvals and guidelines.• Maintain hydrology at streamcrossings through approvedmethods for culvert installation.• Implement erosion andsediment control.• Invasive species management.• Implement progressivereclamation and restoration.Change in Mortality RiskConstruction • No hunting or harassment by personnel.• Implement Avifauna ManagementPlan to address incidental take.Operation andMaintenance andDecommissioningand Reclamation• On-site vehicle speed limits.• No hunting or harassmenton the Project site.• On-site vehicle speed limits.• Use welding mats from April 1 toNovember 15 to prevent forest fires.• Dispose of all waste appropriately.• Limit lighting to that requiredfor safe operation.• Shield exterior lights from above.DirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA L S LT O I U/D N HA L S LT O I U/D N HA L S LT O I U/D N HRecommended Follow‐upand Monitoring• Monitor for complianceof mitigation measures.• Monitor for complianceof mitigation measures.• Monitor for complianceof mitigation measures.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 99

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryProject PhaseChange in HealthConstructionOperation andMaintenanceDecommissioningand ReclamationMitigation / Compensation Measures• Consider clearing by mulching andmechanized forestry equipment.• Use best practices for fuels and otherhazardous materials such as herbicides.• Implement various dustcontrol measures.• Consider clearing by mulching andmechanized forestry equipment.• Use best practices for fuels and otherhazardous materials such as herbicides.• Implement various dustcontrol measures.• Do not bury waste duringprogressive reclamation activities.• Confirm equipment arrives onsite free from fluid leaks.• Inspect and maintain equipmenton a regular schedule.• Establish a site for equipmentmaintenance, repair, and cleaningthat is a minimum of 100 m fromany lake, river, stream, or wetland.• Use best practices for fuels and otherhazardous materials such as herbicides.• Implement various dustcontrol measures.• Use best practices for fuels and otherhazardous materials such as herbicides.• Implement various dustcontrol measures.DirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA L S LT O I U/D N HA L S LT O I U/D N HA L S LT O I U/D N HRecommended Follow‐upand Monitoring• Monitor for complianceof mitigation measures.• Monitor for complianceof mitigation measures.• Monitor for complianceof mitigation measures.A – 100

Key:Direction:P Positive - Beneficial or desirablechange in the environment.A Adverse - Worsening or is undesirablechange in the environment.N Neutral - No detectable ormeasureable change in theenvironment.Magnitude:L Low - the residual Project effects(alteration or loss) are not expectedto exceed 5 percent of the knownpopulation in the RSA. No measurableeffect on VEC as a whole.M Moderate - the residual Project effects(alteration or loss) are expected to begreater than 5 percent and not exceed25 percent of the known populationin the RSA and the effect can bemeasured.H High - the residual Project effectsto (alteration or loss) are expectedto exceed 25 percent of the knownpopulation in the RSA; the effect canbe easily observed, measured anddescribed, and may be widespread.Geographic Extent:S Site-specific - Effect confined tothe Project footprint for all Projectcomponents (i.e., PDA), and limitedto directly affected environmentalcomponents.L Local - Effect extends beyond theProject footprint into the surroundingareas within the LSA.R Regional - Effect extends beyondthe LSA into RSA, where indirect orcumulative effects may occur.B Beyond Regional (provincial, national,and/or international extent) - Effectextends beyond the RSA. Area whereindirect or cumulative effects mayoccur.Frequency:O Once - Effect occurs once during thelife of the Project (e.g., clearing).S Sporadic - Effect occurs sporadically,at irregular intervals, without anypredictable pattern during the life ofthe Project (e.g., hydrocarbon spills).R Regular - Effect occurs on a regularbasis and at regular intervals duringthe life of the Project.C Continuous - Effect occurscontinuously.Duration:STShort-term - Effect occurs during thesite‐preparation or construction phaseof the Project (i.e., 1 to 2 years).MT Medium-term - Effect extendsthroughout the construction andoperation phases of the Project (up to15 years).LT Long-term – Effect is greater than 15years.P Permanent – Effect persists.Reversibility:R Reversible – effect is reversible duringthe life of the Project.I Irreversible – a long-term effect that ispermanent (i.e., remains indefinitelyas a residual effect).Environmental or Socio-economic Context:UDUndisturbed - Area relatively or notadversely affected by human activity.Developed - Area has beensubstantially previously disturbedby human development or humandevelopment is still present.N/A Not Applicable.Significance:S Significant.N Not Significant.Prediction Confidence:L Low level of confidence.M Moderate level of confidence.H High level of confidenceNote: (a) Although there are no thresholds to assess the potential alteration / loss of individual listed plants or plant populations,an accepted guideline in the collection of vascular and non-vascular plant voucher specimens is that an immediate population canwithstand the loss of 1 in 20 individuals or 5 percent of a population (Alberta Native Plant Council [ANPC] Native Plant Collection andUse Guidelines 2000).Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 101

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryTable A.8Summary of Project Residual Environmental Effects: Historic and Cultural ResourcesProject PhaseMitigation / Compensation MeasuresDirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextLoss or Alteration to Archaeological and Cultural ResourcesConstruction • Implement EPP in the event ofan unexpected discovery A N/L S P S I U N HOperation andMaintenance A N/L S P S I U N HDecommissioningand ReclamationKey:Direction:N Neutral – no effect on Archaeologicaland Cultural Resources.A Adverse – loss or disturbance ofArchaeological and Cultural Resources.Magnitude:N Negligible – no likely effect onArchaeological and Cultural Resources.L Low – disturbance of Archaeologicaland Cultural Resources but withprior retrieval of the resource andassociated information, and with allnecessary regulatory approvals.M Moderate – disturbance or loss ofa portion of an Archaeological andCultural Resource, with retrieval ofa portion of the resource and itsassociated information, or a directeffect on a known Archaeologicaland Cultural Resource that is ofinterest and concern to the associatedcommunity, but that does not reducethe overall integrity and cultural valueof the site.H High – disturbance or loss of anArchaeological and Cultural Resources,with no retrieval of the resource andits associated information, or a directeffect on Archaeological and CulturalResources, which reduces the overallintegrity and cultural value of the site.SignificancePrediction ConfidenceN/A N/A N/A N/A N/A N/A N/A N/A N/AGeographic Extent:S Site – effect confined to the PDA.L Local – any effect will be limited to theLSA.R Regional – effects may extend beyondthe LSA.Duration:T Temporary – effect will occur butmeasures are taken to salvageand retrieve information from theresources, and/or move / rehabilitatethe site.P Permanent – effect will be permanentand irreversible.Frequency:O Once - effect occurs once.S Sporadically – effect occursoccasionally but not consistentlythroughout the life of the Project.R Regularly – effect occurs at regularintervals throughout the life of theProject.C Continuous – effect will occurcontinuously.Recommended Follow‐upand MonitoringEnvironmental or Socio-economic Context:U Undisturbed – area has been relativelyor not adversely affected by recenthuman activity.D Disturbed – Area has beensubstantially previously disturbed byrecent human development or humandevelopment is still present.N/A Not Applicable.Significance:S Significant.N Not Significant.Prediction Confidence:L Low level of confidence.M Moderate level of confidence.H High level of confidence.A – 102

Table A.9Summary of Project Residual Environmental Effects:Current Use of Lands and Resources for Traditional Purposes by Aboriginal PersonsProject PhaseMitigation / Compensation MeasuresChange in Activity Distribution (Location and/or Timing)Construction • On-going engagement with Aboriginalcommunities and organizations.Operation and • No hunting and fishing policyMaintenance for on-site Project workers.Decommissioning • Progressive rehabilitation.and ReclamationChange in Overal Activity LevelsConstructionOperation andMaintenanceDecommissioningand Reclamation• On-going engagement with Aboriginalcommunities and organizations.• Possible work rotations / culturalleave provisions and culturalactivities in the workplace.DirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceN - - N - - D N HN - - N - - D N HN - - N - - D N HN - - N - - D N HN - N - - D N HN - N - - D N HResulting Change in Overall Quality and Cultural Value of the ActivityConstruction • On-going engagement with Aboriginalcommunities and organizations.N - - N - - D N HOperation andMaintenanceN - - N - - D N HDecommissioningand ReclamationN - - N - - D N HRecommended Follow‐upand Monitoring• On-going engagement withAboriginal communitiesand organizations.• On-going engagement withAboriginal communitiesand organizations.• On-going engagement withAboriginal communitiesand organizations.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 103

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryKey:Direction:P Positive.A Adverse.N Neutral (or No Effect).Magnitude:L Low: affects a small group of users.M Moderate: affects less than themajority of users across multipleactivities.H High: affects the majority of landand resource users across multipleactivities.Geographic Extent:S Site: includes PDA and 200 m beyond.L Local: LSA.R Regional: RSA.Frequency:N Not likely to occur.O Once: Occurs once.S Sporadic: occurs sporadically.R Regular: occurs on a regular basis.C Continuous.Duration:S Short term: construction phase only.M Medium term: continues throughoperation and maintenance phase.L Long term: continues beyondoperation and maintenance.P Permanent.Reversibility:R Reversible.I Irreversible.Environmental or Socio-economic Context:U Undisturbed: Area relatively or notadversely affected by human activity.D Developed: Area has beensubstantially previously disturbedby human development or humandevelopment is still present.Significance:S Significant.N Not Significant.Prediction Confidence:L Low level of confidence.M Moderate level of confidence.H High level of confidence.N/A Not Applicable.A – 104

Table A.10Summary of Project Residual Environmental Effects:Other Current Use of Lands and ResourcesProject PhaseChange in AccessConstructionMitigation / Compensation Measures• Install navigation signage for streamcrossings and in-water Project features• Work with local snowmobile andcross country ski organizationsto address Project effects.• Work with cabin owners to addressProject effects on accessDirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceRecommended Follow‐upand MonitoringA R S C M R D N H • Continue engagementOperation andA/P I S N M R D N H with local resource userMaintenancegroups such as the localDecommissioningsnowmobile club andand Reclamation P/A L S ST S/P R D N H cross country ski club.Change in Level of Activity / UseConstructionOperation andMaintenanceDecommissioningand ReclamationChange in Cabin UseConstructionOperation andMaintenanceDecommissioningand Reclamation• Manage dust and noise• Implement a no harvesting and firearmsprohibition policy on Project site• Work with local snowmobile andcross country ski organizationsto address Project effects• For reasons of public safety theopen pit will remain restricted atdecommissioning, with a bermconstructed around its perimeterand signage will be posted and,• Site decommissioning will includeremoval of rail, contouring of wasterock disposal areas, and re-vegetationof these areas and the TMF• Manage dust and noise;• Conduct an inventory ofexisting cabins and owners;• Continue engagementwith cabin owners;• Install navigation signage for streamcrossings and in-water Project features;• Work with local snowmobileorganizations and cabin ownersto address Project effects;• Develop Blasting Plan; and• Work with cabin owners to addressProject effects on access.Change in ViewscapeConstruction • South Rose Waste Rock Disposal AreaOperation andMaintenanceDecommissioningand Reclamationwas moved to minimize viewshedeffects on residents of FermontA R S C S R D N HA N L C M R D N HP I S C P R D N HA R S C P R D N HA R L C L R D N HP L L C P R D N HA R L C M R D N HA R L C M R D N HP I L C P R D N HKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 105

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryProject PhaseMitigation / Compensation MeasuresChange in Designated Land UseConstruction • Alderon will engage in ongoingdiscussions with LabradorOperation andCity and Wabush.MaintenanceDecommissioningand ReclamationKey:Direction:P Positive.A Adverse.N Neutral.Magnitude:L Low (affects a small group of land andresource users).M Moderate (affects less than themajority of land and resource usersacross multiple activities).H High (affects the majority of landand resource users across multipleactivities).Geographic Extent:S Site: within the PDA.L Local: within the LSA.R Regional: within the RSA.DirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA R S C M R D N HA N S C M R D N HP I S C L R D N HFrequency:N Not likely to occur.O Once: Occurs once.S Sporadic: occurs sporadically.R Regular: occurs on a regular basis.C Continuous.Duration:S Short-term (restricted to constructionphase).M Medium-term (continues throughoperations and maintenance phase).L Long-term (16 to 50 years).P Permanent.Reversibility:R Reversible: the effect can be reversedto existing conditions.I Irreversible: the effect cannot bereversed.Recommended Follow‐upand MonitoringEnvironmental or Socio-economic Context:U Undisturbed: Area relatively or notadversely affected by human activity.D Disturbed: Area has been substantiallypreviously disturbed by humandevelopment or human developmentis still present.Significance:S Significant.N Not Significant.Prediction Confidence:L Low level of confidence.M Moderate level of confidence.H High level of confidence.N/A Not Applicable.A – 106

Table A.11Summary of Project Residual Environmental Effects: Community Services and InfrastructureProject PhaseMitigation / Compensation MeasuresMunicipal Services and Infrastructure (Western Labrador)Construction • Accommodation strategy• On-site medical servicesOperation and• Transportation arrangementsMaintenance• Human resource policies and practicesDecommissioning• Liaison with agenciesand ReclamationMunicipal Services and Infrastructure (Fermont)Construction • Accommodation strategy• On-site medical servicesOperation and• Human resource policies and practicesMaintenance• Liaison with agenciesDecommissioningand ReclamationHousing and Accommodations (Western Labrador)Construction • Accommodation strategy• Transportation arrangementsOperation and • Human resource policies and practicesMaintenance• Liaison with agenciesDecommissioningand ReclamationHousing and Accommodations (Fermont)Construction • Accommodation strategy• Transportation arrangementsOperation and• Human resource policies and practicesMaintenance• Liaison with agenciesDecommissioningand ReclamationKey:Direction:P Positive.A Adverse.Magnitude:L Low: A change experienced by lessthan 5 percent of households.M Moderate: A change experienced by 5percent to 33 percent of households.H High: A change experienced by morethan 33 percent of households.Geographic Extent:WL Western Labrador.L Labrador.F Fermont.DirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceRecommended Follow‐upand MonitoringA L WL MT C N/A N/A N H • Alderon will liaise withlocal authorities andA M WL LT C N/A N/A N M provide updates onProject activities andA L WL MT C N/A N/A N H plans on a regular basis.AAALLLFFFMTLTMTCCCN/A N/AN/A N/AN/A N/ANNNHHH• Alderon will liaise withlocal authorities andprovide updates onProject activities andplans on a regular basis.A M WL MT C N/A N/A N H • Alderon will liaise withlocal authorities andA M WL LT C N/A N/A N M provide updates onProject activities andA L WL MT C N/A N/A N H plans on a regular basis.AAALLLFFFMTLTMTCCCN/A N/AN/A N/AN/A N/ANNNHHH• Alderon will liaise withlocal authorities andprovide updates onProject activities andplans on a regular basis.Duration:ST Short-term.MT Medium-term.LT Long-term.P Permanent – will not change back tooriginal condition.Frequency:O Occasionally, once per month or less.S Occurs sporadically at irregularintervals.R Occurs on a regular basis and atregular intervals.C Continuous.Reversibility:R Reversible.I Irreversible.N/A Not Applicable.Environmental or Socio-economic Context:U Undisturbed: Area relatively or notadversely affected by human activity.D Developed: Area has beensubstantially previously disturbedby human development or humandevelopment is still present.N/A Not Applicable.Significance:S Significant.N Not Significant.Prediction Confidence:L Low level of confidence.M Moderate level of confidence.H High level of confidence.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 107

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryTable A.12Summary of Project Residual Environmental Effects: Health and Community HealthProject PhaseMitigation / Compensation MeasuresChanges in Air Quality (Which Could Affect Human Health)Operation and • Refer to Chapter 14,Maintenance Atmospheric Resources(Representative ofall Project phases)Changes in Water Quality (Which Could Affect Human Health)Operation and • Refer to Chapter 16, Water ResourcesMaintenance(Representative ofall Project phases)Changes in Soil Quality (Which Could Affect Human Health)Operation andMaintenance(Representative ofall Project phases)• Refer to Chapter 14,Atmospheric ResourcesChanges in Vegetation Quality (Which Could Affect Human Health)Operation and • Refer to Chapter 14,Maintenance Atmospheric Resources(Representative ofall Project phases)Change in Public Safety (Injuries / Accidents)Construction • Project site access restrictions• Transportation systems,new access roads• Planning and communicationOperation andMaintenanceDirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA L L M C R D N MA L S M C R D N MA L L P C R D N MA L L M C R D N MA(N)A(N)L L S S R D N HL L M S R D N HDecommissioningand Reclamation N - - - - - - - -Change in Substance AbuseConstructionOperation andMaintenanceDecommissioningand Reclamation• Use of a resident workforcewherever possible.• Workforce accommodations plan• Community and cultural informationand training for workers• Employee assistance program• Drug and alcohol testing,as legally allowed• Continued cooperation with localand regional communities andagencies and service providersRecommended Follow‐upand Monitoring• Continue with existingair quality monitoringprograms in the LSA.• Continue with currentbaseline surfacewater monitoringprograms in the LSA.• Continue with existingair quality monitoringprograms in the LSA.• Continue with existingair quality monitoringprograms in the LSA.• Continued cooperationand communicationwith local and regionalcommunities andagencies and serviceproviders. Provision ofProject information asrequired and requested.AANLL-LL-SM-SS-RR-DD-NN-HH-• Continued cooperationand communicationwith local and regionalcommunities andagencies and serviceproviders. Provision ofProject information asrequired and requested.A – 108

Project PhaseChanges in CrimeConstructionMitigation / Compensation Measures• As aboveDirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA L L S S R D N HOperation andMaintenance A L L M S R D N HDecommissioningand Reclamation N - - - - - - - -Changes in Perceptions of Quality of Life and Well-BeingConstruction • As aboveOperation andMaintenanceA /PA /PL L M S R D N HL L M S R D N HDecommissioningand Reclamation N - - - - - - - -Key:Direction:P Positive.A Adverse.N Neutral (or No Effect).Magnitude:L Low: affects a small number of persons,and may be indistinguishable fromthe normal condition and/or naturalvariability of the VEC;).M Moderate: effect is detectable withina population, but is within normalrange of variability and/or is withinregulatory limits / standards and/orobjectives.H High: effect cause clear and sustainedexceedences of regulatory limits /standards and/or objectives).Geographic Extent:S Site: includes PDA and 200 m beyond.L Local: LSA.R Regional: RSA.Frequency:N Not likely to occur.O Once: Occurs once.S Sporadic: occurs sporadically.R Regular: occurs on a regular basis.C Continuous.Duration:S Short-term: construction phase only .M Medium-term: continues throughoperation and maintenance phase.L Long-term: continues beyondoperation and maintenance.P Permanent.ReversibilityR Reversible.I Irreversible.Reversibility:R Reversible.I Irreversible.Recommended Follow‐upand Monitoring• Continued cooperationand communicationwith local and regionalcommunities andagencies and serviceproviders. Provision ofProject information asrequired and requested.• Continued cooperationand communicationwith local and regionalcommunities andagencies and serviceproviders. Provision ofProject information asrequired and requested.Environmental or Socio-economic Context:U Undisturbed: Area relatively or notadversely affected by human activity.D Developed: Area has beensubstantially previously disturbedby human development or humandevelopment is still present.Significance:S Significant.N Not Significant.Prediction Confidence:L Low level of confidence.M Moderate level of confidence.H High level of confidence.N/A Not Applicable.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 109

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryTable A.13Summary of Project Residual Environmental Effects: Economy, Employment and BusinessProject PhaseEconomyConstructionMitigation / Compensation MeasuresDirectionMagnitude• Benefits Plan and DiversityPlan provisions. P HOperation andMaintenance P HDecommissioningand Reclamation P LEmploymentConstruction• Benefits Plan and DiversityPlan provisions. P HOperation andMaintenance P HDecommissioningand Reclamation P LBusinessConstruction• Benefits Plan and DiversityPlan provisions. P HOperation andMaintenance P HDecommissioningand Reclamation P LResidual EnvironmentalEffects CharacteristicsGeographic ExtentLWLNLLWLNLLWLNLLWLNLLWLNLLWLNLLWLNLLWLNLLWLNLDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceMT C N/A N/A S HLT C N/A N/A S HST C N/A N/A S HMT C N/A N/A S HLT C N/A N/A S HST C N/A N/A S HMT C N/A N/A S HLT C N/A N/A S HST C N/A N/A S HRecommended Follow‐upand Monitoring• As per Benefits Planand Diversity Plan• As per Benefits Planand Diversity Plan• As per Benefits Planand Diversity PlanA – 110

Key:Direction:P Positive.A Adverse.Magnitude:L Low: A change experienced by lessthan 5 percent of households.M Moderate: A change experienced by 5percent to 33 percent of households.H High: A change experienced by morethan 33 percent of households.Geographic Extent:LW Economic Zone 2.L Labrador.NL Province.Duration:ST Short-term.MT Medium-term.LT Long-term.P Permanent – will not change back tooriginal condition.Frequency:O Occasionally, once per month or less.S Occurs sporadically at irregularintervals.R Occurs on a regular basis and atregular intervals.C Continuous.Reversibility:R Reversible.I Irreversible.N/A Not Applicable.Environmental or Socio-economic Context:U Undisturbed: Area relatively or notadversely affected by human activity.D Developed: Area has beensubstantially previously disturbedby human development or humandevelopment is still present.N/A Not Applicable.Significance:S Significant.N Not Significant.Prediction Confidence:L Low level of confidence.M Moderate level of confidence.H High level of confidence.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 111

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APPENDIX BComplete Record of all CommentsIdentified During Consultation andEngagement Activities with ResponsesKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 113

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryTable B.1Issues Raised by Aboriginal Groups and Stakeholders – Project DescriptionIssueEngineering andProject DesignMining OperationsCommunity/OrganizationCabin OwnersFermontWabushFermontCabin OwnersCabin OwnersFermontInnu NationCabin OwnersCabin OwnersWabush /Fermont /Lab CitySummary of Comments Raised DuringConsultation and Engagement ActivitiesAre there alternatives to the proposedinfrastructure locations?Why is Alderon proposing infrastructure in thisconfiguration?Why weren’t alternative routes / locations chosen?Why does the road follow the railway as opposedto going straight, would there be a safety issueassociated with travel along the railway?Have alternate access road options been explored?Why use Elephant Head Road and Jean Lakeinstead of Duley Lake, as currently used? Concernof proximity of Project infrastructure to Grenfell Dr.Would it be possible to put a conveyor instead ofa railway?How often will blasting occur and will it besynchronized with other mines?At the Mount Wright ArcelorMittal mine, there isa required evacuation of all personnel for a 1000marea when blasting occurs. There may be issuesassociated with communication regarding blastingto ensure no one is in the area.What will be the safety perimeter around the pit toensure people safety?Will there be blasting operations on weekends?Please provide better details of actions beingdeveloped to minimize environmental impacts.Potential effects of light from working site, willthere be operations during the night?Is the first time that conveyors are used in thearea, and what is the width of the right of way forconveyors?What will be the height of the conveyor over thelake?Will there be guards around the conveyor toprotect against loss into the lake and for cabinowners travelling to their cabins?I am concerned about safety with regards to speedand the number of trucks using the road.Concerns about safety include child safety dueto increased road and rail traffic, elderly peopleduring construction.Response / Location in EISThe mine site and associated infrastructure wereselected based on the location of the ore body.Key considerations in the selection of locationsfor key Project elements are described in Section2.5. Various alternatives were identified andevaluated based on technical, safety, economic andenvironmental factors, as described in Section 2.8.This is not considered to be a technically andeconomically feasible option, given the distancesand costs involved. The mine site and associatedinfrastructure were selected based on the locationof the ore body. Key considerations in the selectionof locations for key Project elements are describedin Section 2.5. Various alternatives were identifiedand evaluated based on technical, safety, economicand environmental factors, as described in Section2.8.Following the EA approval, a Blasting Plan willbe developed and implemented in compliancewith all applicable laws, regulations and industrybest practices, and with consideration of safety,environmental and social issues, as identifiedthrough the EA.See Section 2.6.2.The purpose of the EA process is to identifymitigation measures to avoid or reduceenvironmental issues and effects. These aredescribed throughout this EIS, and summarized inChapter 27.Certain aspects of Project construction andoperations will occur 24 hours per day. Lightemissions and their potential effects are assessed indetail in Chapter 14.Conveyors are commonly used in similar miningoperations. Conveyors will be covered to minimizefugitive emissions (e.g., dust, debris). Conveyorcharacteristics (locations, dimensions) and their useare described in detail in Section 2.5.2.Safety is a number one concern for Alderon, allemployees, contractors (including truck operators)are required to comply with Alderon’s Health andSafety Policy and procedures. This includes avoidinguse of existing roadways where possible.See Sections 2.5.5, 2.6.1, and 24.6.1.1B – 114

IssueEconomic FeasibilityAccidents andMalfunctionsAccess roadCommunity/OrganizationWabushWabush / InnuNationCIM ConferenceCIM ConferenceFermontCabin OwnersLe mouvementcitoyen deFermontLabrador CityFermontSummary of Comments Raised DuringConsultation and Engagement ActivitiesResponse / Location in EISWith the competition and expansion of otherProjects such as IOC’s genesis Project, do you thinkAlderon will make it to the market in time?Based on Project characteristics, schedule and30% of iron seems like a low percentage. Is itcurrent market conditions, this Project is viable andeconomical / profitable to develop this Project?economically attractive. Section 2.2 outlines someIs the price of iron ore expected to increase?of the key economic considerations and conditionsWhat price would iron need to be to make thewhich are relevant to the Project.Project profitable?Are you concerned that analysts predict the ironprice will go down in a few years?Has your PEA been signed by a qualified person inregards to the 43-101 standard?At the end of the predicted mine life, what are yougoing to do with your employees?Alderon should provide proof to the public thatthe Québec claims are sterile. Otherwise it leadsto suspicion that Alderon is hiding something bydropping the claims.Concern about the tailings pond effluentdischarging into Duley Lake and contaminating it.In case of an accident, what measures will be inplace to inform the people of Fermont of risksand mitigate the situation? If an incident happensin Québec, the MDDEP informs the communitythrough a press release.Concern that the roadway is located in closeproximity to the water source.Cabin owner suggested Project should have roadto mine from Fermont to shorten drive to work.Alderon personnel and contractors areappropriately qualified and skilled for theirrespective roles.Section 1.1 describes the Project’s proponent andits overall management structure and some keypersonnel/positions.Section 2.7 provides information on the Project’santicipated construction and operations workforce,including the timeframes and durations for eachactivity/position.The Kami property is located entirely in Labrador.Mining activity in Québec is not part of thecurrent Project as proposed. See Section 2.4 for adescription of the Project location and associatedmineral licenses.Alderon will treat all effluent to meet regulatorystandards prior to release into the environment.The key characteristics and features of the TailingsManagement Facility and effluent treatmentinfrastructure are described in Section 2.5.4 and2.6.2. The potential effects of any such accidentalevents are assessed in Chapter 16 and others.In the event of an accidental event or malfunction(e.g., spill), Alderon will inform and communicaterelevant agencies and potentially affectedcommunities as required, in accordance with theirEnvironmental Protection Plan and emergencyresponse plans. Avoidance and responseprocedures for accidental events are describedin Chapters 5, 8 and others and consideredthroughout the EIS.The design and construction of the roadway willbe in compliance with all applicable regulatorystandards, including buffer zones. This issue, andmeasures to mitigate any potential effects to waterresources, are assessed in detail in Chapter 16.The mine site and associated infrastructure wereselected based on the location of the ore body.Key considerations in the selection of locationsfor key Project elements are described in Section2.5. Various alternatives were identified andevaluated based on technical, safety, economic andenvironmental factors, as described in Section 2.8.Such a road is not considered to be a technicallyand economically feasible option.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 115

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryRailIssueTailingsimpoundmentCommunity/OrganizationInnu NationLabrador CityCabin OwnersWabush /Labrador CityWabush/Labrador CityLabrador CityWabushCabin OwnersFermont /WabushInnu NationSummary of Comments Raised DuringConsultation and Engagement ActivitiesWould Alderon get rights on railway and wouldthey upgrade the railway?Will Alderon use the current rail system orconstruct their own?An important issue for me is that I feel the railwayis too close to the Town of Wabush.How will the rail line affect new town expansion?Has Alderon considered other alternatives, such asconnecting to Wabush mines, on the west side ofJean Lake?Concern that the rail line is located in closeproximity to the water source and wetland / bogsmay cause contamination due to materials seepinginto water.There should be guards at road crossing for therailway to ensure safety. Alderon should not onlymeet the requirements, but set the bar high.My cabin is on Loon Lake and I am worried abouttailings.What is the location of tailings? Concern about thelocation of tailings nearby residents and cabins. Isit possible to relocate the tailings?Alderon should put a fence around the tailings andthe pit to avoid that wildlife such as caribou andpartridge go in these areas and eat the tailings.Response / Location in EISThe Project is planned to utilize the existing QNS&Lrailroad, and does not include proposed upgradesto that infrastructure. Alderon’s proposed newrailway infrastructure will tie into the QNS&Lrailway as described in Sections 2.5.7 and 2.6.2.To address this issue, Alderon moved the rail linefurther away from the Town of Wabush to minimizeinteraction with future town development plannedin the southeast area. The potential effects(including vibration) of the railway operations aremodeled and described in Chapter 14.The rail line was moved further away from thenortheast Section of Wabush to reduce potentialinteractions with future town development.Key considerations in the selection of locations forkey Project elements are described in Section 2.5.Various alternatives were identified and evaluatedbased on technical, economic and environmentalfactors, as described in Section 2.8.The design and construction of the roadway willbe in compliance with all applicable regulatorystandards, including buffer zones. This issue, andmeasures to mitigate any potential effects to waterresources and wetlands, are assessed in detail inChapter 16 and 17.Safety is a number one concern for Alderon. Therail line as currently designed does not cross theTrans Labrador Highway or any other provincial/municipal paved road ways. The proposed railinfrastructure is described in Section 2.5.7.Alderon will treat all effluent to meet regulatorystandards prior to release into the environment.The key characteristics and features of the TailingsManagement Facility and effluent treatmentinfrastructure are described in Section 2.5.4 and2.6.2.The proposed Tailings Management Facility islocated west of Riordan Lake in the eastern portionof the Project area. See Figure 2.5 in Section 2.5for an overall site plan. Key considerations in thedesign and planning of the Tailings ManagementFacility are described in Section 2.5.4. Variousalternatives were identified and evaluated basedon technical, economic and environmental factors,as described in Section 2.8.The Tailings Management Facility will be containedby a series of natural ridges and containmentdams/dykes. Key considerations in the design andplanning of the Tailings Management Facility aredescribed in Section 2.5.4. Chapter 19 includes anassessment of potential effects to wildlife and theirmitigation.B – 116

IssueTailingsimpoundment(continued)Location oftransmissionAvailability of powerLocation of wasterock pilesCommunity/OrganizationLabrador CityWabushWabushLabrador City /WabushUashatFermontFermont /Wabush / LabCitySummary of Comments Raised DuringConsultation and Engagement ActivitiesConcern about the effect of tailings on waterincluding Riordan Lake, wetland / bogs and nearbywater system. Could tailings overflow or seep intowater? What will happen to fish?Has Alderon given consideration to using tailings tocreate bicycle and walking trails for residents, as ithas been done for other projects?Concern of location of the transmission or powerline along lake and possible effects to recreation,and nearby residents (within 1 km). Possiblehealth effects, and on water supply. Could thetransmission line be relocated?Concern about power requirements, how muchis needed and will Nalcor be able to provide asufficient amount over the life of the Project?Can the Project recall power back from Québec?How Alderon is addressing the power issue andwhere they will get their power?Will Alderon need to build a transmission line, andif so, does the EIS cover the transmission line andaccess to power?Will the abandonment of claims on Québec sidechange the shape for the waste?Can the waste rock be relocated away fromFermont?Response / Location in EISAlderon will treat all effluent to meet regulatorystandards prior to release into the environment.The key characteristics and features of the TailingsManagement Facility and effluent treatmentinfrastructure are described in Section 2.5.4 and2.6.2. The potential effects of any such accidentalevents are assessed in Chapter 16 and others.Chapter 18 includes an assessment of potentialeffects to fish and their mitigation.Use of tailings for recreational activities is notfeasible. Alderon will work with the municipalitiesto determine recreational infrastructureimprovements. Information on recreationalinfrastructure is provided in Chapter 24.The design and construction of the transmissionline will be in compliance with all applicableregulatory standards, including buffer zones. Keyconsiderations in the design and planning of thetransmission line are described in Section 2.5.6.The operations phase of the Project will see anoverall demand for power in the order of 100-120MW. The Project power requirements and themanner in which they will be addressed (optionsby Nalcor Energy), including responsibility forpermitting and constructing any new transmissionline(s) are described in Section 2.5.6.The Project does not include Project componentsor activities in Québec. This will not affect theProject as designed and presented in this EIS. SeeSection 2.5.3 for details about the design andlocation of the waste rock disposal areas.The location of the waste rock disposal areas havebeen selected (and was subsequently revised)based on this issue and associated consultationswith residents. See Section 2.5.3 for details aboutthe design and location of the waste rock disposalareas.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 117

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryTable B.2Issues Raised by Aboriginal Groups and Stakeholders – Atmospheric EnvironmentIssueChange in AirQualityCommunity/OrganizationWabush /FermontFermontWabush /FermontSummary of Comments Raised DuringConsultation and Engagement ActivitiesConcerns about potential effects on air quality, airpollution and effect on quality of life. Questionsasked:• Are there measures to minimizeatmospheric pollution from the variouscomponents associated with mining?• Will the Project diminish quality of lifeand purity of air on the territory?• What will you do if air quality isaffected? Will you close the mine?Toxic plumes are associated with blasting, whatwill you do if it comes to Fermont?Will the air inhaled be safe with people withrespiratory illnesses in the Town of Fermont?Will toxic emissions from blasting be transportedby wind to the Fermont and neighbouring Québecterritory?Questions about air quality monitoring:• Explain air quality programs, including rationalefor monitoring locations, parameters, etc.• Does the Alderon mine foresee measures(sensors) to ensure that the qualityof air of the Town of Fermont?• Will tools used to monitor air quality bemade available for public consultation?Response / Location in EISPotential effects to air quality from the Project havebeen assessed in the EIS. The main effect fromthe Project on air quality will be increased level ofdust. Mitigation measures for all potential effects,including dust emissions have been identified,including dust suppression, equipment preventativemaintenance programs, and engineering controlssuch as covered conveyors, as required. Emissionsfrom the blast site will be monitored to ensure theyare within regulatory limits.Results of the assessment of effects on theatmospheric environment are provided in Section14.6. Chapter 25 of the EIS has evaluated physicalhealth and community health (including quality oflife) associated with mine operations.The distance between Fermont and the openpit, where blasting would mainly occur, is 5km. Emissions from blasting will become lessconcentrated as they leave the mine site. Emissionsfrom the blast site will be monitored to ensure theyare within regulatory limits. This means that theconcentrations of emissions will be comparable tonormal combustion sources used by residents, suchas woodstoves and barbecues.Details on the nature of emissions is provided inSection 14.6. Chapter 25 of the EIS has evaluatedphysical health, and community health (includingquality of life) associated with mine operations.Alderon conducted baseline programs for airquality to characterize existing conditions of theatmospheric environment that could be affectedby the Project. In addition to using data fromexisting monitoring stations, Alderon installedmonitoring stations on the shores of Long Lake,Wabush and Fermont. This data was used to modeldispersion of particulate matter resulting fromthe Project. Parameters measured included totalparticulate matter, PM2.5 and PM10. A monitoringprogram will be implemented during operations,comparable to that used in similar industries.Results are provided in Section 14.5. Additionaldetails on baseline air quality data and theproposed monitoring program are provided inSection 14.10 and Appendix EB – 118

NoiseDustIssueCommunity/OrganizationFermont / LabCity / Wabush /Cabin OwnersFermontLe mouvementcitoyen deFermontLabrador City /WabushSept-ÎlesCabin OwnersSummary of Comments Raised DuringConsultation and Engagement ActivitiesConcern about noise pollution from air and othertransportation, blasting and operations by cabinowners (Round Rail, Riordan Lake), residents,and recreation users at Duley Park. Communitymembers can hear and feel blasting from othermines (ArcelorMittal mine, IOC) that are locatedfurther away than the Project so they areconcerned about noise effects from operationsthat are very close. Questions asked:• How could it be possible not tobe affected by your mine?• Will the noise break windows or dishes?• Will blasting for the Project wouldbe heard in Fermont, or in thesurrounding recreational areas?At the Mont Wright ArcelorMittal mine (whereparticipants work), there is a required evacuationof all personnel for a 1,000-m area when blastingoccurs. Participant identified that there may beissues associated with communication regardingblasting to ensure no one is found in the area.• Are measures in place to reduce noise effects?• Have studies been undertaken on theeffects of noise on the Town of Fermont?• Will Alderon follow noise limits developedby the L’organisation Mondial de laSanté (World Health Organization)?Where the railway crosses the road, will therebe a whistle? If so, this may have an effecton community members by creating noisedisturbance.Are the requirements for dust, noise, etc. differentin Newfoundland than in Québec?Dust is an issue of importance. Since theConsolidated Thompson operation started, dustis now coming into the Duley area for the firsttime. Concern that winds will send dust all over.Several cabin owners expressed concern with theprevailing winds blowing dust towards Wabushfrom the tailings impoundment. Suggestion that anew town site may be required.Cabin owners are expecting compensation fornoise and dust.Response / Location in EISNoise levels have been measured and predictedcarefully to help design the Project and to ensurethey are within regulatory limits. Following the EAapproval, a Blasting Plan will be developed andimplemented in compliance with all applicablelaws, regulations and industry best practices, andwith consideration of safety, environmental andsocial issues as identified throughout the EIS.Noise predictions are provided in Section 14.6 andinformation on the Blasting Plan is provided inSection 2.6.2.Warnings are issued in the affected area using loudsignalling devices before blasts are initiated andaudible. Potential effects from blasting activities arediscussed in Section 14.6.Noise levels have been predicted for the Town ofFermont and will be within the regulatory limitseven during highest levels of mine operation.Noise predictions have been provided in Section14.6.Train whistle signals are required by railwayregulation at all public crossings at grade and asrequired to warn trespassers on the right-of-way.The proposed rail line does not include any publiccrossings at grade thereby reducing the potentialfor train whistle noise. See Section 2.5.7 for moredetails on the proposed rail line.The Project is being designed to meet federaland provincial guidelines, including those ofNewfoundland and Labrador and Québec.See Section 14.2.3 for an overview of relevantregulations and guidelines.Dust emissions have been measured and predictedin the assessment so that the Project design willcomply with the prescribed limits. Alderon willimplement mitigation to reduce significant adverseenvironmental effects on properties. Dust emissionmodelling and control technologies are discussed inSection 14.6.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 119

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryIssueDust(continued)Greenhouse GasEmissionsCommunity/OrganizationFermont / LabCity / Wabush/Cabin OwnersNNKWabushSummary of Comments Raised DuringConsultation and Engagement ActivitiesDust from operations, tailings, road traffic andblasting is an issue of main concern for all threecommunities. Questions asked:• What are the plans for dust management?• How do these plans take prevailingwinds and storms into consideration?Participants suggested dust mitigation includingrevegetation, and altering the placement of wasterock material when wind is coming from thenortheast.In Schefferville, dust from the tailings is a majorissue.• What will be the effects ofdust from this Project?• What kind of engineering controlmeasures will be put In place?Could the silty sand from the tailings be used tomake concrete or other construction purposes?Characterization of existing ground quality—willwatering of road create run-off?Inquiry about incorporation of more eco-friendlymining alternatives: alternatives to fossil fuels formine fleet; off-setting electrical usage with solar orwind energy; use of composite rail ties.Response / Location in EISIn the EIS, potential effects from dust are predictedand assessed. Weather conditions were includedin the assessment by considering three full years ofweather data, including prevailing wind and otherconditions. Based on the results of this assessment,mitigation measures have been identified tomanage dust from tailings, blasting and traffic.During operations, four full time water trucks willbe used to control dust on the roads. The TMF willbe managed to control dust through moisture,revegetation and other management practices.Conveyors will be covered to minimize dust. Moredetail on dust management and control is providedin Section 14.6.Alderon will progressively revegetate the tailingsmanagement facility and materials will notbe available for other uses. However, Alderoncould consider alternative uses as appropriate.Information on the TMF is available in Section 2.5.4and 2.6.2.The road material presents no hazard from runoff.Watering rates will be managed to maximizeeffectiveness and minimize wasted runoff.The processing facilities and excavators for theProject are drawing on electrical energy thatwill be substantially renewable in origin, fromhydroelectric generating stations. GHG emissionshave been assessed and compared with provincialtotal and national total. This analysis is provided inSection 14.6.B – 120

Table B.3Issues Raised by Aboriginal Groups and Stakeholders – Landforms, Soils, Snow and IceIssueCommunitySummary of comments raised duringconsultation and engagement activitiesResponse / Location in EISIn the EIS, the potential for acid rock drainage(ARD) and metal leaching has been determined tobe very low. The assessment included results frombaseline sampling and the experience of nearbyiron ore mine operations. There are sections of theore deposit that contain sulphides which have theAcid Rock Drainageand Metal Leaching General General potential to generate ARD. Ongoing monitoringof tailings discharge, run-off and mine water willbe conducted throughout the life of the mine toensure that discharges meet regulatory standards.If ARD is determined to be an issue, appropriatemitigation will be identified and implemented.Details are provided in Section 15.6 and 16.6.Control measures on-site will limit the particulateemissions to meet all regulatory standards. Bycontrolling particulate emissions from Projectactivities, the deposition of dust on the snowpackLe mouvementwill be greatly reduced. Due to the composition ofAre there measures taken to protect the snowcitoyen dethe ore, no adverse residual environmental effectsfrom pollution from mine residues?Fermontare expected. This assessment has been conductedbased on predicted emissions during the mostactive period of the mine.Snow and IceDetails on control measures are presented inSection 15.6.FermontRehabilitation Fermont FermontWhat are the effects on ice on Daviault Lake duringblasting?Following the EA approval, a Blasting Plan willbe developed and implemented in compliancewith all applicable laws, regulations and industrybest practices, and with consideration of safety,environmental and social issues as identifiedthroughout the EIS. This issue has been addressedin Section 15.6 and information on the Blasting Planis provided in Section 2.6.2.Yes, a Financial Assurance, as set out in Section 10of the Mining Act and addressed in Section 8 of theMining Regulations will be set aside to cover thecosts for all activities included in the DevelopmentPlan, the Rehabilitation and Closure Plan, aswell as those activities required for on-going sitemonitoring and maintenance. Information onthe Rehabilitation and Closure Plan is provided inSections 2.6.4 and 8.1.12.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 121

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryIssueRehabilitation(continued)Cumulative EffectsCommunityFermontFermontLe mouvementcitoyen deFermontWabushInnu ofMatimekushLac-JohnFermontSummary of comments raised duringconsultation and engagement activitiesFermontFermontLe mouvement citoyen de FermontWabushInnu of Matimekush Lac-JohnResponse / Location in EISA Rehabilitation and Closure Plan has beenprepared at a feasibility level and will be revised toa detailed design level prior to Project constructionand development. Preliminary details on closureand decommissioning activities are presentedin the Project Description in Section 2.6.4.Information on the Rehabilitation and Closure Planis provided in Sections 2.6.4 and 8.1.12.The aim of the Rehabilitation and Closure Planis to create the necessary conditions for there-establishment and long-term propagation ofindigenous native species in the areas disturbedby Alderon development and operation activities.Disturbed areas will be graded and contoured; asoil cover will be applied where it is considerednecessary for vegetation growth; and vegetationwill be established of similar density and diversityas that which exists in proximate areas. Furtherdetails on planned rehabilitation activities arepresented in Section 2.6.4.The open pit will be decommissioned with theobjective of long-term stability. Flooding of the pitwill be allowed to occur naturally. The pit’s wallswill be excavated to a stable slope angle (“designingfor closure”) during mining operations. Pit slopeswill be graded and contoured above and just belowthe final water surface for safety and access overportions of the pit perimeter. Further details areprovided in Section and 2.6.4.As detailed in Section 14.5 (AtmosphericEnvironment), the prevailing winds for the area,as recorded at the Wabush Airport, are from thewest and the south, with winds blowing from theParticipant is concerned with the proximity ofnortheast towards Fermont only approximatelythe proposed Project to the Town of Fermont.5 percent of the time. As well, it has been shownFermont is already exposed to dust from operatingthrough dispersion modelling that the air qualitymining sites further away from the proposedzone of influence for the proposed Project is limitedProject location. Provides example of Labrador Cityto the Project site and a few hundred metersresidue “red snow” resulting from mining activity.beyond and therefore would not likely overlap withthe zones of influence of the other nearby minesto result in a cumulative effect on the Town ofFermont.B – 122

Table B.4Issues Raised by Aboriginal Groups and Stakeholders – Water ResourcesIssueCumulative Effectson Water ResourcesPotentialContamination ofWater BodiesCRECommunityMouvementCitoyen deFermontCabin OwnersFermontCREWabushSummary of comments raised duringconsultation and engagement activitiesLac Daviault is the head of the Moisie Riverwatershed, what would be the dust, red water andcumulative effects on that watershed?Alderon should consider cumulative impacts onthe entire northern region. Fermont is alreadysurrounded by four iron mines and adding onemore would contribute to additional dust andcontamination of lakes and environment.An important issue for me is potential impacts tothe lakes systems.Concern that Bloom Lake project has contaminatedtwo adjacent lakes.Will water bodies flowing into Lac Daviault beimpacted?Will the Moisie River headwaters be affected?Lac Daviault is the head of the Moisie Riverwatershed, what would be the effects of dust, redwater and cumulative effects on that watershed?Springs all through Daigle Point.How will tailings run off in the polishing pondaffect Duley Lake / Long Lake to the north West?Response / Location in EISIn the EIS, potential effects and mitigation for WaterResources have been assessed and identified.Lac Daviault is not in the same watershed as theProject, therefore there are no potential cumulativeeffects to the Lac Daviault/ Moisie River watershed.See Section 16.6 and 16.7 for more informationabout this assessment. Alderon will also implementseveral dust management and control measures tominimize dispersion of dust.More detail on dust management and control isprovided in Section 14.6.Water quality effects of the Project were reviewedin the EIS including the potential for increasedsediment loading, ARD and metal leaching,ammonia contamination and red water. Effluenttreatment system will be used at the TMF, andeffluent will monitored for compliance withregulatory limits. No residual or cumulative waterquality effects are predicted.See Section 16.6 and 16.7 for more informationabout this assessment.Mine effluent will be treated in compliance withregulatory standards, minimizing impacts to lakereceiving waters. There will be no surface waterrunoff from the Project to Lac Daviault, thereforeno surface water impacts are anticipated. LacDaviault is not in the same watershed as Project,therefore there is no potential for red water releaseto the Lac Daviault/Moisie River watershed.See Section 16.6 for more information about thisassessment.Lac Daigle is several kilometres to the west of theProject location in a separate watershed and willnot be affected by the Project.Section 16.5 includes a description of the existingenvironment that may be affected by the Project.The TMF will include a tailings pond followed bya polishing pond for sedimentation (settling) offine particles. The residence time of water movingthrough these ponds is very long and thereforethey will be able to remove particles to very smallsizes. However, due to the potential for red waterfrom the Project TMF, a flocculating red watersystem will be constructed at the polishing pond tofurther reduce particulate to extremely small sizes.This treatment system will ensure the provision ofvery low Total Suspended Solids concentrationsto Long Lake/Duley Lake. The potential for acidrock drainage, metal leaching and ammoniacontamination from TMF runoff is low and notconsidered a potential water quality effect.See Section 16.6 for more information about thisassessment.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 123

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryIssuePotentialContamination ofWater Bodies(continued)CommunityLabrador CityLe mouvementcitoyen deFermontFermontFermontSummary of comments raised duringconsultation and engagement activitiesConcern that overflow of tailings will go intoRiordan Lake.What measures are in place to contain waterdischarge from the mine onto the surroundingterritory?In the event of contamination of waters on theQuébec territory, what measures are in place torestore/remediate contaminated areas?Are measures in place to protect Lake Perchard?How will Alderon Corp assure that groundwater isnot contaminated in the region?If you add a mountain of waste over a mountain,will it modify the watershed?What about the groundwater? Is it located in thesame watershed?Resident likes to swim/dive amongst the ice.Will the concentration process require the use ofchemicals? Is there a risk of contamination?Response / Location in EISAlderon will treat all effluent to meet regulatorystandards prior to release into the environment.The key characteristics and features of the TMFand effluent treatment infrastructure are describedin Section 2.5.4 and 2.6.2. All discharges from theTMF and polishing pond will flow north into LongLake and are therefore are not anticipated to affectRiordan Lake or Québec.See Section 16.6 for more information about thisassessment.Surface water and groundwater divides will not bealtered by the waste rock disposal areas. Disposalareas straddling two watersheds will be graded topreserve existing watershed divides to the extentfeasible.See Section 16.6 for more information about thisassessment.Existing recreational activities are not expected tobe adversely affected by the Project. See Section23.6 for more information.Alderon will treat all effluent to meet regulatorystandards prior to release into the environment.Non-toxic flocculant use is expected to reduce thepotential for fine particulate red water. Floccedparticulate will be collected in the red watertreatment system. Chemical processes would becontained in building or within mill yard, with spillcontainment and stormwater drainage system.The key characteristics and features of the TMF andeffluent treatment infrastructure are described inSection 2.5.4 and 2.6.2.B – 124

IssuePotentialContamination ofWater Bodies(continued)CommunityLabrador CityInnu NationWabushSummary of comments raised duringconsultation and engagement activitiesThe placement of the Rose Pit in the middle of anidentified stewardship management area. Lookat remedial steps that can be taken to minimizehabitat loss prior to construction phase.What is the planned compensation for the watersystem that Rose Pit will occupy? There is quite alot of water in the water system.Will the bog material be removed prior to the useas tailings impoundment?If the bog material is removed, will the tailingsseep into the groundwater or into the lake?Alderon will need to be cautious of bogs andstreams around the mine, to make sure they donot flow in lakes and contaminate them.Will there be equipment and supplies (forcontainment and recovery) located immediatelynext the railway on site, in the event of a spill?Response / Location in EISAlderon will enter into a Corporate StewardshipAgreement with the municipalities and the EasternHabitat Joint Venture to mitigate loss of alternateManagement Units.See Section 19.6.5 for more information aboutthe assessment of potential effects and proposedmitigation for change in protected areas.Alderon will enter into a Corporate StewardshipAgreement with the municipalities and the EasternHabitat Joint Venture to mitigate loss of alternateManagement Units. See Section 19.6.5 for moreinformation about the assessment of potentialeffects and proposed mitigation for change inprotected areas. Alderon will also prepare aCompensation Plan as required under the FisheriesAct. See Section 18.6 for more information.Headwater areas above the Rose Pit footprint willbe preserved with clean water bypass diversionaround the open pit. Headwater ponds will bemonitored for water level effects. For moreinformation see Section 16.6.Stripping of organic soils and overburden isrequired to provide a structurally sound base fortailings dams and dykes. This activity also minimizesthe potential for dam seepage. Tailings seepagewater is not expected to have sedimentation,ARD, metal leaching, ammonia contamination orred water concerns. See Section 16.6 for moreinformation about the assessment and mitigationof effects on water resources.Alderon will treat all effluent to meet regulatorystandards prior to release into the environment.The key characteristics and features of the TMF andeffluent treatment infrastructure are described inSection 2.5.4 and 2.6.2. See Section 16.6 for moreinformation about the assessment and mitigationof effects on water resources.Alderon has developed a detailed spillmanagement plan that will include preventiondesign and practices, training, spill monitoringand surveillance, spill containment, collection,remediation and reporting. Spill containmentand collection equipment will be kept on site andlocated strategically to ensure the most expeditiousspill response.See Section 16.8 for more information.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 125

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryIssuePotentialContamination OfWater SupplyPotential Effects onWater QualityCommunityCabin OwnersFermont /Wabush / LabCityLabrador CityCabin OwnersCabin Owners /Fermont / LabCityWater Management FermontSummary of comments raised duringconsultation and engagement activitiesAn important issue to me is the potential fortailings to affect Quaniniche (our water supply).Concern about spills or run-off from rail,transmission or tailings potentially occurring inwater supply/watershed area. There is no back upwater supply for Wabush. Require a contingency tobe in place. Questions include:• How you will treat the tailings so it doesn’tleach into the drinking water supply?• Can surface water in the lake be affected?We take water from this lake.The proposed road power line and rail line runthrough the Jean Lake management area andadjacent to the water supply and watershed inclose proximity to residents. Consider an alternateroute for rail line.Will the water quality of lakes be affected? Willthere be any impact on the watershed?What will be the effects to water quality, includingLong Lake, Lac Daviault and Mills Lake?Is there the potential for a spill or tailings drainagecontamination of the local watershed?What will happen to the watershed if the lakeis removed? Alderon should do preliminaryinvestigation of active dewatering to reducefootprint and simplify reclamation e.g. centrifuge.What are the water sources for the Project andhow will water be managed?Response / Location in EISThe TMF is located primarily in the Long Lakewatershed and is contained by a series of naturalridges, dams and dykes. All discharges from theTMF and polishing pond will flow north into LongLake and are therefore are not anticipated to affectthe Wabush Public Water Supply.The primary risk to the Town of Wabush watersupply would be from a spill from the access roadand rail infrastructure. In the case of an accident ormalfunction, Alderon has developed an emergencyresponse plan, to minimize, mitigate and remediateany effects of a potential spill to the Wabush watersupply. See Sections 16.6, 16.8 and 23.8 for moreinformation.Alderon will treat all effluent to meet regulatorystandards prior to release into the environment.The key characteristics and features of the TMFand effluent treatment infrastructure are describedin Section 2.5.4 and 2.6.2. No adverse effects areanticipated to receiving water lakes or watersheds.See Section 16.6 for more information about theassessment and mitigation of effects on waterresources.The TMF is located primarily in the Long Lakewatershed and is contained by a series of naturalridges, dams and dykes. All discharges from theTMF and Polishing Pond will flow north into LongLake and are therefore not anticipated to affect LacDaviault or Mills Lake.Rose Lake will be removed as part of the open pitdevelopment. Headwater runoff from the Projectlocation will be diverted around the open pit. A netincrease in runoff to Pike Lake South is expecteddue to open pit dewatering.Alderon will treat all effluent to meet regulatorystandards prior to release into the environment.The key characteristics and features of the TMFand effluent treatment infrastructure are describedin Section 2.5.4 and 2.6.2. No adverse effects areanticipated to receiving water lakes, including LongLake, or watersheds.See Section 16.6 for more information about theassessment and mitigation of effects on waterresources.The water sources for the Project are:• Harvesting runoff water from the TMF;• Long Lake;• Open pit dewatering; and• Local groundwater pumping wells.A Water Management Plan is being developedto maximize the reuse of mine contact waterin ore processing, dust suppression and othernon-potable water uses. Further, the ore processrecycles water many times to ensure that waterconservation is maximized and that effluentdischarge is minimized.See Section 2.6.2 and 16.6 for more information.B – 126

Table B.5Issues Raised by Aboriginal Groups and Stakeholders – WetlandsWetlandsIssueWetlandStewardship AreaCommunityLab City /WabushWabush /Fermont / LabCitySummary of comments raised duringconsultation and engagement activitiesParticipants identified wetlands as an issue ofconcern.How can loss of habitat be avoided in theconservation area? Or how will habitats withinthe conservation area be replaced? Mitigationmeasures proposed included dedicating a newwetland, use of money for interpretation sites,viewing area for Wabush narrows, education, cleanup of historically impacted areas, mitigations, etc.Response / Location in EISWetlands are common throughout the Projectarea, and the region. Overall, no wetland types willbe lost completely as a result of Project activities.Some mitigation measures to address Projecteffects on wetland include minimizing interactionwith wetlands by restricting construction activitiesto the PDA, maintaining natural drainage wherepossible and conduct progressive rehabilitation andwetland restoration.The assessment of Project effects on wetlands isprovided in Section 17.6.Alderon will enter into a Corporate StewardshipAgreement with the municipalities and theprovince (through the Eastern Habitat JointVenture) to address the effects of the Project onManagement Units. Possible mitigation measuresfor the effect on wetland habitat include fundingeducation programs, interpretation sites, viewingareas at the Wabush narrows, dedicating anew wetland stewardship area or rehabilitatinghistorically impacted areas.Additional information is provided in Section 17.6.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 127

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryTable B.6Issues Raised Regarding Freshwater Fish, Fish Habitat and FisheriesIssueCumulative effectson fish and fishhabitatFish population andspeciesFish habitatCommunityInnu NationWabushCabin OwnersLe mouvementcitoyen deFermontInnu NationLabrador CitySummary of comments raised duringconsultation and engagement activitiesMost elders and land users are afraid to hunt inthe Wabush area because of the landscape andpollution. They are scared to eat the fish andanimals. In the spring, summer and fall, Innu gohunt in that area. They are concerned with whatpartridges, beavers and other animals eat there.They are also concerned with contamination offish.Will the Project have effects on fish?3-4 lb speckled trout are caught in area lakes.An important issue for me is community impactdue to the destruction of aquatic life.What measures will be taken to protect theaquatic system?Alderon needs to be cautious of bogs and streamsaround the mine, to make sure they do not flow inlakes and contaminate them.Concern of fish migration between the small lakessouth of Mills Lake to Mills Lake and Molar Lake.What will happen to fish in the proposed tailingsareas and nearby water system?How is fish habitat replaced?There is a water system south of Riordan Lake thatthe local people fish. Concerns that the tailingsarea is just north of the water body and that itmight affect fish.Response / Location in EISExisting land and resource use by Aboriginalpersons and potential health effects are discussedin Sections 22.5 and Chapter 25 of the EIS. Inthe EIS, potential effects to fish have also beenassessed and mitigation identified. The Projectis not anticipated to result in heavy metal orchemical contamination. See Section 18.6 for moreinformation about this assessment.In the EIS, potential effects to fish have beenassessed and mitigation identified. This assessmentdetermined that fish mortality as a result of theProject is not anticipated. Alderon will prepare aCompensation Plan as required under the FisheriesAct. See Section 18.6 for more information.In the EIS, potential effects to fish have beenassessed and mitigation identified. This assessmentdetermined that changes to trout populationsare not anticipated. See Section 18.6 for moreinformation.In the EIS, potential effects to fish have beenassessed and mitigation identified. This assessmentdetermined that there will be minimal destructionof aquatic life as a result of the Project. UnderMetal Mining Effluent Regulations, effluent mustbe tested monthly to verify that it is not acutelylethal to fish or Daphnia (water flea). Alderonwill prepare a Compensation Plan as requiredunder the Fisheries Act. See Section 18.6 for moreinformation.Alderon will treat all effluent to meet regulatorystandards, including Metal Mining EffluentRegulations, prior to release into the environment.The key characteristics and features of the TMF andeffluent treatment infrastructure are described inSection 2.5.4 and 2.6.2. See Section 16.6 for moreinformation about the assessment and mitigationof effects on water resources.The Project will not block passage of fish fromMills Lake to Molar Lake. See Section 18.6 for moreinformation.Alderon will prepare a Compensation Plan asrequired under the Fisheries Act. Fish will berelocated from areas to be dewatered. See Section18.6 for more information.The TMF is located primarily in the Long Lakewatershed and is contained by a series of naturalridges, dams and dykes. All discharges from theTMF and polishing pond will flow north into LongLake and are therefore not anticipated to affectfish habitat outside of the footprint watershed,including Riordan Lake.B – 128

Table B.7Issues Raised by Aboriginal Groups and Stakeholders – Birds,Other Wildlife and their Habitat, and Protected AreasIssueCumulative Effectson Wildlife SpeciesPotential Effects onwildlife SpeciesCommunityInnu NationNNKInnu NationInnu Nation ofMatimekush-LacJohnNNKSummary of comments raised duringconsultation and engagement activitiesMost elders and land users are afraid to hunt inthe Wabush area because of the landscape andpollution. They are scared to eat the fish andanimals. In the spring, summer and fall, Innu gohunt in that area. They are concerned with whatpartridges, beavers and other animals eat there.They are also concerned with contamination offish.There are cumulative effects from all of theprojects in the area on the George River caribouherd.Alderon needs to make sure the land is protectedand that the environmental impacts are minimal.Alderon should put a fence around the tailingsand the pit to prevent wildlife (e.g. caribou andpartridge) that go in these areas from eating thetailings.Concern about potential effects of the Projecton caribou. Caribou are presently hunted nearSmallwood reservoir.Community members have followed caribou intoLabrador in the past and may again in the future.The caribou once came through the communitybut not anymore (there were 900,000 caribou,now there are around 80,000). One caribou cameinto the community over Christmas, and this wasthe first in 6 years.There are cumulative effects of all projects in thearea on the George River caribou herd. The Projectwill potentially affect the George River herd, whichis located just outside of the limits of Wabush.Response / Location in EISExisting land and resource use by Aboriginalpersons and potential health effects are discussedin Sections 22.5 and Chapter 25 of the EIS. In theEIS, potential effects to birds and wildlife have alsobeen assessed and mitigation identified.See Section 19.6 for more information about thisassessment.This herd does not currently overlap the Projectarea, therefore potential effects from the Projectare not anticipated. The range of the George Rivercaribou herd is discussed in Section 19.5.3.The purpose of the EA process is to identifymitigation measures to avoid or reduceenvironmental issues or effects. These aredescribed throughout the EIS and summarized inChapter 27.The TMF will be contained by a series of naturalridges and containment dams/dykes. Keyconsiderations in the design and planning of theTMF are described in Section 2.5.4 and 2.6.2.Section 19.6 includes an assessment of potentialeffects to wildlife and their mitigation.Caribou herds do not currently overlap the Projectarea, therefore potential effects from the Projectare not anticipated. The range of the George Rivercaribou herd is discussed in Section 19.5.3.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 129

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryIssuePotential Effects onwildlife Species(continued)Potential Effects onWaterfowlPotential Effects onWildlife HabitatCommunityLabrador City /WabushCabin OwnersLe mouvementcitoyen deFermontInnu NationSummary of comments raised duringconsultation and engagement activitiesSpecific wildlife sightings reported by communitymembers: lynx in southwest corner area;wolverine in area but no fisher; wolves (>6)are going around in circles around community;Mourning Dove (first sighting in 1981); AmericanRobin (seen in Labrador West until Christmas);Eastern Bluebird (sighting in November); GraycheekedThrush (sightings to the east) Bald Eagle(probable nest around Dolomite quarry); GreatHorned Owl (nest is located on north end ofRiordan Lake); Boreal owl (common); Hawk Owls(further east); phalaropes; bats (20-40 at cabin);marmot; and wolverine (uncertain); Great HornedOwl, Snowy Owl, otters, lynx, marmot, muskrat,moose. Barred Owl (great horned owl) nesting.Specific wildlife sightings reported by communitymembers: wood duck are rare but active inincinerator gully; Harlequin duck are in Jean Lakeand Wabush Pond during migration bird count;diver (June-October).An important issue for me is community impactdue to the destruction of wildlife.Is the Québecois territory at risk of deforestation inthe future by the Alderon mine?Alderon needs to be cautious of bogs and streamsaround the mine to make sure they do not flow inlakes and contaminate themResponse / Location in EISA description of existing wildlife is provided inSection 19.5. Baseline data collection for the EISincluded aerial surveys for waterfowl completed in2011, songbird survey completed in 2011 and 2012,and winter aerial surveys in 2012. Potential effectsto wildlife have been assessed and mitigationidentified.See Section 19.6 for more information about thisassessment.Existing land and resource use is discussed inSections 23.5 of the EIS. In the EIS, potential effectsto birds and wildlife have also been assessed andmitigation identified.See Section 19.6 for more information about thisassessment.Alderon has no plans to harvest timber. A completelist of Project activities are included in Section 2.6.Alderon will treat all effluent to meet regulatorystandards, including Metal Mining EffluentRegulations, prior to release into the environment.The key characteristics and features of the TMF andeffluent treatment infrastructure are described inSection 2.5.4 and 2.6.2.See Section 16.6 for more information about theassessment and mitigation of effects on waterresources.Labrador City /WabushAre the potential effects of the Project on wildlifebeing studied?What will be the effects on Jean Lake?Will there be any effect on the wildlife at Mills Lakefrom tailings drainage?Jean Lake rapids will use existing crossing, dustwill be controlled, and effects will be mitigated toexisting area of effect. Effluent will be treated toensure compliance with release criteria and will betested monthly. Additional information is presentedin Chapter 19 and 20.B – 130

Table B.8Issues Raised by Aboriginal Groups and Stakeholders – Species atRisk and Species of Conservation ConcernIssuePotential Effects onSpecies at RiskPotential Effects onCaribouCommunityLabrador City /WabushInnu NationNNKSummary of comments raised duringconsultation and engagement activitiesSpecific wildlife sightings reported by communitymembers: Harlequin duck are in Jean Lake andWabush Pond during migration bird count; andGray-cheeked thrush (sightings to the east).Alderon should put a fence around the tailingsand the pit to prevent wildlife (e.g. caribou andpartridge) that go in these areas from eating thetailings.Community members have followed caribou intoLabrador in the past and may again in the future.The caribou once came through the communitybut not anymore (there were 900,000 caribou,now there are around 80,000). One caribou comeinto the community over Christmas, and this wasthe first in 6 years.There is a third herd of caribou that has beenidentified by a Québec biologist Natalie d’Astousnear the Québec -Labrador border. This herd couldbe affected by the Project.Response / Location in EISA description of existing wildlife is provided inSection 19.5. Baseline data collection for the EISincluded aerial surveys for waterfowl completed in2011, songbird survey completed in 2011 and 2012,and winter aerial surveys in 2012. Harlequin Duckwas not observed during these surveys but wasreported at Jean Lake Rapids by a stakeholder.Section 20.5 includes a description of speciesat risk and of conservation concern within theProject area. Potential effects to species at risk andmitigation measures are identified in Section 20.6.The TMF will be contained by a series of naturalridges and containment dams/dykes. Keyconsideration in the design and planning of theTMF are described in Section 2.5.4. Sedentaryherds of caribou are not present within the Projectarea and are therefore not anticipated to beaffected by the Project.Section 20.5 includes a description of existingspecies at risk and of conservation concern that arefound within the Project area.Sedentary herds of caribou are not present withinthe Project area and are therefore not anticipatedto be affected by the Project.Section 20.5 includes a description of existingspecies at risk and of conservation concern that arefound within the Project area.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 131

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryTable B.9Issues Raised by Aboriginal Groups and Stakeholders – Historic and Cultural ResourcesIssueDisturbance ofarchaeological sitesPotential effects onburial sitesCommunityFermontLabrador CitySummary of comments raised duringconsultation and engagement activitiesArrow heads were reported to have beenfound at an unconfirmed location on Lac d’Aiglenear Fermont, Québec. It was reported by theinformant that the artifacts were analyzed anddated to the first Innu.Concern that there is a cemetery on the route.Response / Location in EISSection 21.5 includes a description of historicaland cultural resources in the vicinity of the Project.The closest point on Lac d’Aigle to the Project isapproximately 7.3 km away and therefore is notanticipated to be affected by the Project. Section21.6 includes the assessment of effects from theProject on archaeological sites.Section 21.5 includes a description of historicaland cultural resources in the vicinity of the Project.Background research and informant interviewsdid not identify any information to suggest thereis a cemetery in the vicinity. However, there is acemetery with a cross located south of the Projectarea that is a registered archaeological site with theProvincial Archaeology Office. The Innu visit thesite frequently and maintain the cemetery, whichis located approximately 70 km southeast of theProject. This site is not anticipated to be affected bythe Project. Section 21.6 includes the assessmentof effects from the Project on burial sites.B – 132

Table B.10Issues Raised by Aboriginal Groups and Stakeholders – Current Use ofLands and Resource for Traditional Purposes by Aboriginal PersonsIssueCumulative Effectson Use of Landsand Resources forTraditional Purposesby AboriginalPersonsPotential Effects onTraditional Land UseActivitiesCommunityInnu of Uashatmak Mani-UtenamInnu NationNaskapi Nationof KwawachikamachInnu NationInnu ofMatimekush -Lac JohnNaskapi Nationof KwawachikamachInnu NationSummary of comments raised duringconsultation and engagement activitiesExpressed concerns about other mining companiesin area and cumulative effects on traditionalterritory. Cumulative effects are particularlyimportant to address. Community membersfeel more and more dispossessed of their land.Comments included:• We thought development on our territorywas over. Is still room for other companies inthat area? Alderon said they would take careof the environment, but we cannot use theland in that area anymore. Everything hasbeen destroyed, water and animals. Somepeople go on land just for wellbeing andthis cannot be done any more in this area.Alderon could contribute in the Innu Nationcommunity by providing funding for an outpostprogram for Innu who want to participate inharvesting activities.Alderon should set aside money for communitymembers to hunt in areas far from theircommunity (i.e., for skidoos). The caribou oncecame through the community but no longer. Atone point there were 900,000 caribou; now thereare around 80,000.In the spring, summer and fall, communitymembers hunt in the area. They are concernedwith what partridges, beavers and otheranimals eat there. They are also concerned withcontamination of fish.The Project overlaps with their traditional territory.There are potential effects of the Project on landuse in the area.Do not currently practice land use activities in theProject area but still have land claims in Labrador.Currently, the Naskapi do not go into Lab West.Will share maps of their traditional hunting routesand historic sites with Alderon.Alderon could contribute in the Innu Nationcommunity by providing funding to build cabins onthe territory.Response / Location in EISThe purpose of the EA process is to identifymitigation measures to avoid or reduceenvironmental issues and effects. Cumulativeeffects on Current Use of Lands and Resourcesfor Traditional Purposes by Aboriginal Persons areassessed and evaluated in Section 22.8.Alderon’s current Aboriginal engagement processesare described in Chapter 10, and its AboriginalRelations Policy is outlined in Section 1.1.1. Alderonis currently negotiating a benefits agreement withInnu Nation.Alderon’s current Aboriginal engagement processesare described in Chapter 10, and its AboriginalRelations Policy is outlined in Section 1.1.1.A human health risk assessment was completedfor the Project reviewing potential pathways forcontamination. This assessment determined thatthere is a low risk of effect to country foods. Theseissues and analyses are provided in Chapter 25. Anassessment of current land and resource use byAboriginal persons in the Project area is presentedin Chapter 22.An assessment of current land and resource use byAboriginal persons in the Project area is presentedin Chapter 22.Information on current land and resource use thathas been made available to Alderon is presentedin Chapter 22. Existing land and resource use andthe status of land claims are described in Sections22.2.3 and 22.5.Alderon’s current Aboriginal engagement processesare described in Chapter 10, and its AboriginalRelations Policy is outlined in Section 1.1.1. Alderonis currently negotiating a benefits agreement withInnu Nation.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 133

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryIssuePotential Interactionwith ExistingAboriginal Rights /TitleCommunityInnu NationInnu ofMatimekush -Lac JohnNaskapi Nationof KwawachikamachInnu of Uashatmak Mani-UtenamInnu ofMatimekush -Lac JohnInnu of Uashatmak Mani-UtenamSummary of comments raised duringconsultation and engagement activitiesConsider all of Labrador as their traditionalterritory and will not surrender their rights.Project overlaps with their traditional territory.They have an unresolved land claim deep inLabrador territory. They have followed the caribouinto Labrador in the past and may again in thefuture.Confirm that the Project area is claimed territoryas it is located within their ancestral territory. Theirtraditional families own the land covered by theProject.Wish to be engaged separately from the Innuof Uashat mak Mani-Utenam, even thoughthey share the same territory. Any benefitagreement must be negotiated with both groupsindependently.Are there other Aboriginal groups involved on theKami Project?Response / Location in EISAn assessment of current land and resource use byAboriginal persons in the Project area is presentedin Chapter 22. Existing land and resource use andthe status of land claims are described in Sections22.2.3 and 22.5.Alderon is committed to building mutuallybeneficial and respectful relationships with allAboriginal groups. Alderon’s current Aboriginalengagement processes are described in Chapter10, and its Aboriginal Relations Policy is outlined inSection 1.1.1.B – 134

Table B.11Issues Raised by Aboriginal Groups and Stakeholders –Other Current Use of Lands and ResourcesIssueVisual AestheticsCommunityCabin OwnersCIM Conference/ Fermont / Lemouvementcitoyen deFermontFermontLabrador CityLabrador City /WabushWabushSummary of comments raised duringconsultation and engagement activitiesParticipants concerned they will be able to seemine from their propertiesMining in Labrador, but most of the negativeimpacts are going to be on the Fermont side.Concern that the Project will create visualpollution, particularly waste rock pile. Desire topreserve untouched visual aesthetic in Fermont.Questions include:Will the mine manage the site in a manner thatmakes it not visible from Fermont?What will I see from my home?For the visual aesthetics study, two points of viewshould be assessed:from Fermont.from top of hill by Lac d’Aviault.A lot of people hike there and there is a beautifulviewpoint we would not want compromised by thewaste rock pile.Concern that other lakes will have the same visualimpact issue as Wabush Lake.Will there be any visible impacts to the Duley LakePark area (e.g. such as trucks driving around orwaste rock piles)?Power lines are a visual issue.Response / Location in EISViewshed analyses and before and afterphotosimulations of the Project from select vantagepoints have been included in the EIS. These showthat the Project will be minimally visible from thethree municipalities. The Project will be visible fromsome cabin locations.See Section 23.6.4 for the viewshed analysis andphotosimulations.To minimize effects on the citizens of Fermont, theRose South Waste Rock Disposal has been relocatedapproximately 5 km to the east.Due to the relocation of the Rose South Waste RockDisposal Area, the Project will be minimally visiblefrom Fermont. A before and after photosimulationwas completed for Fermont, from the westernshore of Lac Daviault and from the peak of MontDaviault. This simulation showed that the Project isminimally visible.See Section 23.6.4 for the viewshed analysisand photosimulations. Section 2.5.3 includes adescription of the waste rock disposal area.Alderon will treat all effluent to meet regulatorystandards prior to release into the environment.In addition, the treatment is designed to minimizered water. The key characteristics of theTMF andeffluent treatment infrastructure are describedin Section 2.5.4 and 2.6.2. The issue of red waterand measures to mitigate any potential effects areassessed in detail in Chapter 16.Viewshed analyses and before and afterphotosimulations of the Project from selectvantage points have been included in the EIS. Basedon the viewshed analysis, it is not likely that theProject will affect the view from the camp groundsnear the Duley Lake Provincial Park Reserve at thenorthwestern end of Long Lake. The Rose SouthWaste Rock Disposal Area will be minimally visiblefrom the dock at the Duley Lake Provincial ParkReserve.See Section 23.6.4 for the viewshed analysis andphotosimulations.Viewshed analyses and before and afterphotosimulations of the Project from select vantagepoints have been included in the EIS. Based onthe viewshed analysis, the power line will likely bevisible from adjacent areas. However, the powerline was relocated along the road/rail right-of-wayto limit visual effects from the Jean Lake hiking trail.See Section 23.6.4 for the viewshed analysis andphotosimulations.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 135

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryIssueAccess to PropertyPotential Effects onCabinsCommunityWabush / CabinOwnersCabin Owners/ LabradorWest Statusfor Women /Le mouvementcitoyen deFermont / NNK/ NCCCabin Owners/ Labrador City/ Fermont /WabushLabrador City/ Fermont /WabushSummary of comments raised duringconsultation and engagement activitiesProposed rail line follows current access usedby cabin owners. Many cabin and camp owners,particularly those at Mills Lake are concerned withhow their access will be affected by the railway,conveyor, crusher, and pit. Questions include:Will the proposed road along the rail line be apublic roadway?Will access be provided to cabin properties thatare presently only accessed by ski-doo or ATV?What steps will be undertaken to ensure theiraccess?How soon before cabin owners are evicted?Will Mills Lake Road be plowed for access thiswinter? In the past, a loader clearing snowroughed up the road.Effect of the Project on cabins in an importantissue. There are houses and cabins close to theProject, particularly in the Duley Lake area, thatcould be affected by the Project.What will Alderon do with the cabins that will beimpacted by mines?What measures will be in place to protect cottagesand cabins in the area?Participants want to know if they will losetheir cabins, especially those that are planningrenovations or upgrades to their properties.Questions asked:When / where / how will each cabin owner / cabinbe affected?What will happen to cabins and cabin owners inthe area?How would Alderon compensate cabin owners?How is the value of the cabins determined?Will Alderon meet again with cabin owners?Some people believe that Alderon will compensatefor discomfort, even if owners have access and getto keep their cabins.Suggested mitigation:Relocate owners to private accessible land.Rebuild cabins in another area accessible by roadwith electricity.Concern that the Project will affect the quality ofcabin life due to pollution, noise, vibrations, dustand other effects.Response / Location in EISThe potential Project effects on access, includingsnowmobile trails, are included in the assessmentof the Project on Other Use of Lands andResources. Alderon will work with local user groupsto address Project effects. The rail line will not crossany paved roads.Alderon has been engaging with cabin owners inthe Project area and has developed a strategy tomitigate adverse effects on cabin owners. Alderonwill continue its engagement with cabin ownersto determine appropriate mitigation measures forindividual cabin owners, as applicable.See Section 23.5, and 23.6 for more information.The potential Project effects on cabin use areincluded in the assessment of the Project on OtherUse of Lands and Resources. Alderon has beenengaging with cabin owners in the Project areaand has developed a strategy to mitigate adverseeffects on cabin owners. Alderon will continueits engagement with cabin owners to determineappropriate mitigation measures for individualcabin owners, as applicable.See Section 23.5.2.1, 23.6.3The potential Project effects on cabin use areincluded in the assessment of the Project on OtherUse of Lands and Resources. Alderon has beenengaging with cabin owners in the Project areaand has developed a strategy to mitigate adverseeffects on cabin owners. Alderon will continueits engagement with cabin owners to determineappropriate mitigation measures for individualcabin owners, as applicable.To address concerns about blasting, Alderon hascommitted to developing a Project-specific BlastingPlan. Effects of the Project on the atmosphericenvironment, including air quality, noise, vibrationand dust have been assessed and mitigationmeasures identified. During Project activities, blastnoise and vibration will be monitored and willcomply with regulatory standards.See Section 23.5.2.1, 23.6.3 and Chapter 14(Atmospheric Environment) for more information.B – 136

IssuePotential Effects onCabins(continued)Potential Effects onProperty ValuePotential Effects onFishingPotential Effects onHuntingCommunityLabrador City /WabushCabin OwnersCabin OwnersWabushWabushCabin OwnersSummary of comments raised duringconsultation and engagement activitiesCorrections to cabin map and ownership.Concern about how tailings will affect cabinlocated on Loon Lake.Although Mills is not part of the start upoperations, when will cabins there be affected?How will they be compensated? Do these cabinowners proceed with renovations on their cabinsnow?Cabin owner at Duley wants to get electricity as aresult of the Project.An important issue for me is the depletion ofproperty values.What will effect be on property values by rail,increased traffic and heavy equipment traffic?Concerns identified about Project effects onfishing. E.g. cabin owner utilizes a fishing areanear Rose South Waste Rock disposal area. Is hepermitted access to that location this summer?Will cabin owners in the Mills Lake & Rose areasstill be able to hunt and harvest wood?A participant advised that drillers asked huntersto put their shotguns away, even though huntinghas been taking place there for approximately 30years.Will there be restrictions on hunters that presentlyaccess the area?Response / Location in EISAlderon is conducting an inventory of existingcabins and owners to ensure that the mostaccurate and up-to-date information is in-hand.See Section 23.6.3 for more information.Potential effects to water resources from Projectactivities are assessed in Chapter 16. There are noeffects anticipated on Loon Lake as a result of theProject.The key characteristics and features of the TMFaredescribed in Section 2.5.4 and 2.6.2.See Section 2.4 for Project location.The Project does not include any activity at MillsLake.See Section 2.4 for Project location. Section23.5.2.1 and 23.6.3 include an assessment ofpotential effects on cabins and proposed mitigationmeasures.Alderon has been engaging with cabin owners inthe Project area and has developed a strategy tomitigate adverse effects on cabin owners. Alderonwill continue its engagement with cabin ownersto determine appropriate mitigation measures forindividual cabin owners, as applicable.See Section 23.5.2.1, 23.6.3Given the anticipated population growth inwestern Labrador and existing demand for housing,property values in the municipalities are not likelyto decrease as a result of the Project.Alderon has been engaging with cabin owners inthe Project area and has developed a strategy tomitigate adverse effects on cabin owners. Alderonwill continue its engagement with cabin ownersto determine appropriate mitigation measures forindividual cabin owners, as applicable.See Section 23.5.2. and 23.6.3Project-related disruptions will be minimal duringSummer-2012 as construction is not scheduled tocommence until late 2013, provided EA approval isreceived.See Section 2.6 for more information about theProject Schedule. More information about potentialeffects to fishing activities in the Project area isincluded in Section 23.6.Cabin owners will still be able to continue topractice their land and resource use activities,however there will be access restrictions at theProject site for the safety of both workers and thepublic.See Section 23.5.5, 23.6.2 and 23.6.3.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 137

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryIssuePotential Effects onLand Use ActivitiesPotential EffectsFrom BlastingOperationsCommunityLabrador CityCabin OwnersLabrador CityLe mouvementcitoyen deFermontWabushCabin OwnersLe mouvementcitoyen deFermontFermont / LabCity / Wabush /Cabin OwnersSummary of comments raised duringconsultation and engagement activitiesAre there issues around Duley Lake? Will there bea road access going through Duley Park? There area lot of activities in that area and we are concernedthat the Project will affect this.Participant expressed concern with a proposedhigh voltage power line running behind houses inWabush.How can loss of habitat be avoided in theconservation area? Or how will habitats within theconservation area be replaced?Will water planes still be able to fly and land withno restrictions?There is a high population growth in Wabush.Concerned that with the railway will limit the Townexpansion. Alderon should assess the potentialimpacts of the railway on future town planning.Will there be blasting operations on weekends?Will the time of blasting be coordinated with othermines in the region to avoid blasting all at once?Concern about noise pollution from, blasting bycabin owners (Round Rail, Riordan Lake), residents,and recreation users at Duley Park.Residents can hear operations located furtheraway than the Project so they are concerned aboutnoise impacts from operations that are very close.Will the noise break windows or dishes?Response / Location in EISThere will be no Project roads in Duley LakeProvincial Park Reserve. Access to the Project sitewill be made through the access road located eastof Wabush. In the EIS, potential effects on land-useactivities at Duley Lake Provincial Park Reserve areassessed and mitigation measures are identified.See Section 23.6.1 for information about thisassessment and Section 2.4 for information aboutthe Project location.The location of the proposed power line was reroutedin response to community concerns.See Section 23.6.4 for viewshed analyses andbefore and after photosimulations of the Project,including the power line, from select vantagepoints.Alderon will enter into a Corporate StewardshipAgreement with the municipalities and the EasternHabitat Joint Venture to mitigate loss of alternateManagement Units.See Section 19.6.5 for more information aboutthe assessment of potential effects and proposedmitigation for change in protected areas.Water planes will still be able to use the existingmarinas in western Labrador and Fermont.See Section 23.5 for more information.To address this issue, Alderon moved the rail linefurther away from the Town of Wabush to minimizeinteraction with future town development plannedin the southeast area.See Section 2.5.7 and 2.6.2Following the EA approval, a Blasting Plan willbe developed and implemented in compliancewith all applicable laws, regulations and industrybest practices, and with consideration of safety,environmental and social issues as identifiedthroughout the EIS. There may be blasting onweekends.See Section 2.6.2 for more information.Following the EA approval, a Blasting Plan willbe developed and implemented in compliancewith all applicable laws, regulations and industrybest practices, and with consideration of safety,environmental and social issues as identifiedthroughout the EIS.See Section 2.6.2 for more information.Following the EA approval, a Blasting Plan willbe developed and implemented in compliancewith all applicable laws, regulations and industrybest practices, and with consideration of safety,environmental and social issues as identifiedthroughout the EIS. See Section 2.6.2 for moreinformation.Effects of the Project on the atmosphericenvironment, including air quality, noise, vibrationand dust have been assessed and mitigationmeasures identified. During Project activities, blastnoise and vibration will be monitored and willcomply with regulatory standards.See Section 23.5.2.1, 23.6.3 and Chapter 14(Atmospheric Environment) for more information.B – 138

IssuePotential Effectson RecreationalActivitiesCommunityCabin OwnersCabin Owners/ Fermont / Lemouvementcitoyen deFermontLe mouvementcitoyen deFermontFermontLe mouvementcitoyen deFermontInnu NationSummary of comments raised duringconsultation and engagement activitiesAn important issue is community impact from themovement of heavy equipment in a recreationalarea.Exploration activities have disrupted recreationalactivities.Potential effects on Lac Daviault, recreationalactivities, boating, planned camp ground areimportant for community members. Recreationalactivities occur in proximity to the Project and theyare concerned that it will affect activities.How can you assure that the Fermont marina andswimming activities will not be polluted by miningoperations?There is a trail that goes approximately 2km frompit, will it be affected?What will be the security perimeter to avoid therisks from flying rocks and particles on recreationalareas in the town of Fermont?Request study on the impacts on tourism andrecreational activities during the duration of theProject.Alderon could contribute in the Innu Nationcommunity by providing funding for hockeytournament.Response / Location in EISUse of heavy equipment will be restricted to theProject site and will not travel through designatedrecreational areas such as campgrounds or parks.See Section 23.6.2 for a description of potentialeffects and mitigation measures for recreationalactivities and land use.The effects on noise, including noise fromequipment has also been assessed in the EIS (seeChapter 14, Atmospheric Environment, for thisassessment)The Project will not overlap with Lac Daviault andwill therefore not affect current use of the lake forboating or camping. Based on viewshed analysisonly some waste rock areas will be visible from thewestern shores of Lac Daviault. Although blastingmay be audible, vibrations will not be felt on thewestern shore of Lac Daviault.Modeling of noise levels resulting from the Projectwill not exceed Health Canada guidelines at LacDaviault. Modeling of dust dispersion indicates thatdust levels at Lac Daviault will not be elevated as aresult of the Project.See Section 23.6.2, 23.6.4 and Chapter 14(Atmospheric Environment)The Project will not overlap with waterbodies inQuébec. Modeling also indicates that there will notbe elevated levels of either dust or noise in Québecas a result of the Project.See Section 2.4 for information about the Projectlocation, Section 23.6.2 for the assessment ofactivities/use that may be affected by the Project,and Chapter 14 for details about the assessment ofeffects on the Atmospheric Environment.The Project will not overlap with the trail.See Section 23.5.4 for a description of outdoorrecreation activities that may be affected by theProject, change in access is assessed in Section23.6.1.A security perimeter will be developed andimplemented as part of the Blasting Plan. Rocksand particles resulting from blasting in the open pitare not anticipated to affect the Town of Fermont.Section 23.6.2 for the assessment of activities/usethat may be affected by the Project, and Chapter 14(Atmospheric Environment) for more information.An assessment of effects on recreational useof lands and resources is included in Section23.6.2. An assessment of effects on recreationalinfrastructure within Labrador City, Wabush andFermont is included in Section 24.6.1 (CommunityServices and Infrastructure). An assessment ofeffects on tourism businesses is included in Section26.6 (Economy, Employment, and Business).Alderon is committed to engaging Aboriginalgroups throughout the EA process and the lifeof the Project. Alderon’s current Aboriginalengagement processes are described in Chapter10, and its Aboriginal Relations Policy is outlined inSection 1.1.1.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 139

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryIssuePotential Effectson RecreationalActivities(continued)Potential Effects onSnowmobile TrailsCommunityWabushWabushWabushSummary of comments raised duringconsultation and engagement activitiesAn upset or spill from trains may affect recreationaluse of area.Concerns about proposed changes andaccessibility to snowmobile trails. Proposedrailway will intersect the current snowmobile trails.Snowmobilers do not like dead-end trails, theyprefer loops.Are there any plans for crossing areas, installationof culverts, stop lights or signs? Need to implementproper safety precautions for travel back and forthfrom the mill, as it may interact with snowmobiletrails.Response / Location in EISAlthough a train derailment is unlikely and hasnot been experienced in western Labrador todate, assessment of the potential effects andidentification of mitigation measures for such aderailment on land and resource use is included inthe EIS as part of the assessment of Accidents andMalfunctions.See Section 23.8 and 23.9.3 for more informationabout this assessment.Alderon will work with local snowmobile groups toaddress Project concerns.See Section 23.5.4 and 23.6.1.B – 140

Table B.12Issues Raised by Aboriginal Groups and Stakeholders – Community Services and InfrastructureIssueAvailability ofHousing for WorkersTemporaryConstruction CampIncreased Air TravelCommunityWabush /Fermont / LabCityCabin OwnersLab West Statusof WomenLabrador CityWabushWabushLe mouvementcitoyen deFermontWabush / LabCitySummary of comments raised duringconsultation and engagement activitiesConcerns with Fly-In / Fly-Out policy andtemporary work camps. Support for housing fulltime workers in communities of Labrador Cityand Wabush. Concern with influx of workers inFermont (workforce is fully employed). Questionsinclude:• Where will workers come fromand where will they live?• Will permanent housing be built and if so whatwill happen after the Project is completed?An important issue for me is housing.Main issues include housing, specifically lowincomehousing and availability of constructionworkers to build new houses.Concern about the potential effects of temporaryconstruction workers in Lab West.Will couple’s accommodation be provided duringconstruction?Permanent and temporary housing is an issue.Industry needs to be involved to solve these issues.Temporary workcamps could help with thesevere housing issue but only for temporaryaccommodations during the construction phaseof the Project. There should not be campsdeveloped in residential areas, including HarrieLake subdivision. Work camps shouldn’t impactmunicipal infrastructure (sewage, recreation, etc.)Consultants have provided overtures on wherecamps can go in terms of artesian wells. The Townshould be part of planning and discussion forconstruction camp. There is a land availability issuein Labrador City. Questions include:• Is Alderon considering buildingworkcamps for workers?• Why don’t companies build apartmentsinstead of workcamps that can be usedby residents after the Project?Want sub-contractors to stay in existingworkcamps. Size it to accommodate those people.Camp would be self-sufficient - own sewagetreatment, etc. Alderon would transfer this toWabush once construction phase is complete.Is Alderon planning to build workcamps orimplement a fly-in, fly-out operation?Will measures be in place to ensure that theairport system available to the region is not under‘heavy’ pressure and leading to increase in tariffs?Airport operates one runway and no fire hall islocated at the airport. This restricts the landingof larger aircraft. Concern of increased traffic at /around airport from Project. Request that Alderonlobby to have additional airlines service theairport.Response / Location in EISAlderon will engage with the relevant agenciesand organizations, particularly the LabradorWest Regional Task Force and the Labrador WestCommunity Advisory Panel, to provide Projectinformation and to identify and discuss potentialProject-related implications for local servicesand infrastructure, including those of Projectrelatedin-migration. Alderon will also engagewith government agencies and communities toestablish a Project accommodations strategy, whichwill address housing concerns. The strategy mayinclude measures such as the use of temporaryaccommodations and the development of newhousing. Alderon will consider employing a fly-in /fly-out workforce during the construction phase ofthe Project. During operations and maintenance,Alderon aims to hire a residential workforce.Additional information on housing is provided inSections ; 24.5.13; 24.6.1 and 24.6.2.Alderon will engage with the relevant agenciesand organizations, particularly the LabradorWest Regional Task Force and the Labrador WestCommunity Advisory Panel, to provide Projectinformation and to identify and discuss potentialProject-related implications for local services andinfrastructure, including those of Project-relatedin-migration. Alderon will work with the Town ofWabush to accommodate increased air traffic, andassociated activity at the airport.More information is presented inSections ; 24.5.11; 24.6.1 24.11.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 141

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryIssueIncreased RailwayTrafficIncreased RoadTrafficPotential Effectson CommunityInfrastructureCommunityCIM ConferenceLabrador CityInnu ofMatimakushLac-JohnLe mouvementcitoyen deFermontCabin OwnersWabush /Fermont / LabCityFermont /Lab City / Lemouvementcitoyen deFermontLe mouvementcitoyen deFermontSummary of comments raised duringconsultation and engagement activitiesAren’t you concerned that the QNS&L railway isbecoming over utilised?The actual railway line and its railway are issues ofconcern. Has Alderon consulted with QNS&L aboutthe projected total rail traffic in 2015-2020?Increased traffic from the Project may slow downthe passenger train and delivery of goods (foodand fuel) from Sept-Iles to ScheffervilleWhat measure will be in place by Alderon tominimize the negative impacts concerning the useof Route 389?An important issue to me is that Duncread is beingused and abused with regards to speed and thenumber of trucks.Concern of heavy equipment and increased trafficon Grenfell Drive in Wabush. Concerns includeroad maintenance costs, vibration, propertyvalues, and child safety. The road is alreadyoverloaded. Questions include:• Can the project utilize alternative roads?• Was any consideration given to accessingthe site from Hwy 500 / 389 through DuleyLake provincial park to west of Long Lake?• Could the road be widened andtraffic lights installed?Will blasting affect foundations or municipalinfrastructure? Will you assess all existingfoundations?Will blasting have an impact the communicationtowers and make everyday life difficult to thepeople of Fermont?Response / Location in EISThe capacity of the QNS&L has been studied formany different potential future traffic volumes,including traffic associated with the Project. Thesestudies have identified infrastructure improvementstrategies that will maintain acceptable levels ofservice for all traffic on QNS&L. Implementation ofthese strategies have been incorporated into thenegotiations for a rail haulage contract betweenAlderon and QNS&L.Additional information is found in Chapter 2 andSection 24.5.11.1.Alderon will build a new road to avoid GrenfellDrive to access the mine site, eliminating concernswith increased traffic and safety. The location ofthis road is shown in Section 2.5.5.More information about current traffic conditionsand potential effects from the Project is found inSections 24.5.11; 24.6.1; 24.11.To address concerns about blasting, Alderon hascommitted to developing a Project-specific BlastingPlan. Effects of the Project on the atmosphericenvironment, including air quality, noise, vibrationand dust have been assessed and mitigationmeasures identified. During Project activities,blast noise and vibration will be monitored andwill comply with regulatory standards. Alderon willestablish safety zones for blasting and will followbest practices to minimize damage from blasting.See Section 24.6.1 and Chapter 14 (AtmosphericEnvironment) for more information.Labrador City Impacts on community services and quality of life. Alderon will engage with the relevant agenciesand organizations, particularly the LabradorWest Regional Task Force and the Labrador WestWabushWabushAn increased population of the community willcreate other issues including sewage treatment.No operational sewage plant in industrial area,maybe Alderon can partner for future benefit.Public Works and residents identified potentialand additional wear and tear of public roads dueto project.Community Advisory Panel, to provide Projectinformation and to identify and discuss potentialProject-related implications for local services andinfrastructure, including those of Project-relatedin-migration.Additional information is presented in Sections10.4; 24.6.1, 24.7 and 24.10.Alderon will build a new road to avoid GrenfellDrive to access the mine site, eliminating concernswith increased traffic and safety. The location ofthis road is shown in Section 2.5.5.More information is available in Sections 24.5.11;24.6.1.B – 142

IssuePotential Effectson CommunityInfrastructure(continued)Potential Effects onCommunity ServicesPotential Effectson RecreationalInfrastructureCommunityWabushLab West Statusof WomenFermontWabushInnu NationFermontSummary of comments raised duringconsultation and engagement activitiesRail and road crossing located between Jean Lakeand Wahnahnish Lake is located exactly where thewater pump house is currently situated for theTown of Wabush.The main issues identified included health services,childcare, and community infrastructure (storesand grocery store).Daycare, social impact of mining work and lack ofchildcare, employment issues in the service sector.Others use the services in Fermont such as healthservices, arena, pool, etc. We are worried aboutthe effect of the new project on our municipalservices.In the service sector, it is a challenge to maintainand retain employees. There is a lack of workforceand support services. Industry needs to beinvolved to solve these issues.Fire fighting service was removed from Wabushairport by Transport Canada when jet service wasremoved. Wabush and Labrador City do not havecapacity to provide fire fighting service.Innu Nation have a program in place with Voisey’sBay, where every person over 60 years old getsa monthly allowance of approximately $500.Suggested that Alderon should consider such aprogram, as this has been very helpful for thecommunity.Concern that there are only two good beaches inthe entire area (Fermont and Duley Lake).Need to identify how to enhance quality of life,perhaps with the creation of a new recreationalarea.Potential effects of the Project on land use such assnowmobile and ski.Potential effects on Lac Daviault, recreationalactivities, boating, planned camp ground - theseare important for Fermont community members.Response / Location in EISThe Project road and rail crossing at Jean Lake/ Wahnahnish Lake will make use of an existingcrossing. Alderon is working with the Town ofWabush to ensure that effects on municipalinfrastructure are identified and mitigated.See Section 24.6 for more information.Alderon will engage with the relevant agenciesand organizations, particularly the LabradorWest Regional Task Force and the Labrador WestCommunity Advisory Panel, to provide Projectinformation and to identify and discuss potentialProject-related implications for local services andinfrastructure, including those of Project-relatedin-migration.More information is found in Sections 10.4; 24.5;24.6.1; 24.7.Alderon will engage with the relevant agenciesand organizations, particularly the LabradorWest Regional Task Force and the Labrador WestCommunity Advisory Panel, to provide Projectinformation and to identify and discuss potentialProject-related implications for local services andinfrastructure, including those of Project-relatedin-migration.Additional information is available in Sections 10.4;;24.5.6.Alderon is committed to building mutuallybeneficial and respectful relationships with allAboriginal groups. Alderon’s current Aboriginalengagement processes are described in Chapter10, and its Aboriginal Relations Policy is outlinedin Section 1.1.1. Alderon is currently negotiating abenefits agreement with Innu Nation.Due to their spatial separation, the Project will notinteract with the beach areas on Long Lake andin Fermont. More information regarding Projectlocation is provided in Section 2.4.An assessment of the effects of the Project oncommunity health, including quality of life, isprovided in Section 25.6.Alderon will continue to engage with localsnowmobile groups to address Project concerns.See Section 23.5.4 and 23.6.1.The Project will not overlap with Lac Daviault andwill therefore not affect current use of the lake forboating or camping. Based on viewshed analysisonly some waste rock disposal areas will be visiblefrom the western shores of Lac Daviault.Modeling of noise levels resulting from the Projectwill not exceed Health Canada guidelines at LacDaviault. Modeling of dust dispersion indicates thatdust levels at Lac Daviault will not be elevated as aresult of the Project.See Section 23.6.2, 23.6.4 and Chapter 14(Atmospheric Environment)Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 143

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryIssuePotential Effectson RecreationalInfrastructure(continued)CommunityFermontLabrador CityLabrador City /WabushSummary of comments raised duringconsultation and engagement activitiesThere is a trail that goes approximately 2 km frompit, will it be affected?What are the effects on ice on Daviault Lake duringblasting?Project is located in some of the last wilderness inthe area.Concerns about the potential effects of dust andnoise in the Duley Lake Park are which woulddisturb park owners and users.Response / Location in EISExisting recreational infrastructure within theProject area is described in Section 24.5.9. Accessto the trail is not anticipated to be affected by theProject.To address concerns about blasting, Alderon hascommitted to developing a Project-specific BlastingPlan. Effects of the Project on the atmosphericenvironment, including air quality, noise, vibrationand dust have been assessed and mitigationmeasures identified. During Project activities, blastnoise and vibration will be monitored and willcomply with regulatory standards.See Section 23.5.2.1, 23.6.3 and Chapter 14 formore information.Section 23.5 includes a description of current landuse in the vicinity of the Project. With the exceptionof the two existing mines, western Labrador canbe classified as largely undeveloped. The effects ofthe Project on the use of land and resources areassessed in Section 23.6.Noise levels and dust emissions have beenmeasured and predicted carefully to help designthe Project so that regulatory standards are met.Occasionally, operating noise might be audible inthe distance, but will be within regulatory limitsand monitored routinely for compliance with thoselimits. Mitigation measures for all potential effects,including dust emissions have been identified,including dust suppression, equipment preventativemaintenance programs, and engineering controlssuch as covered conveyors.More information about potential effects of dustand noise are provided in Section 14.6.WabushWabushJean Lake and Elephant Head Road are recreationareas.Potential effects on snowmobile trails. It will beimportant to discuss with snowmobile association.The Project will not overlap with the recreationareas at Jean Lake and Elephant Head Road.Alderon is working with the Town of Wabush toensure that effects on municipal infrastructure areidentified and mitigated.See Section 24.6 for more information.Alderon will work with local snowmobile groups toaddress Project concerns.See Section 23.5 for a description of existingsnowmobiling activity and Section 23.6 for anassessment of Project effects on snowmobiling andassociated mitigation measures.B – 144

Table B.13Issues Raised by Aboriginal Groups and Stakeholders – Health and Community HealthIssueCumulative Effectson Health andCommunity HealthVisual AestheticsCommunityFermontCabin OwnersCIM ConferenceFermontLe mouvementcitoyen deFermontLabrador CityLabrador City /WabushWabushSummary of comments raised duringconsultation and engagement activitiesCumulative effects of all the expansions in currentProject, and with Alderon, potential effects onquality of life in Fermont.Assess cumulative effect of the Project and otherdevelopments on quality of life in Fermont. Thereare currently many different things happening inFermont in terms of development, mining projects,housing.There is a study on the current situation inLabrador regarding the impact on mining onhuman health. Asks the proponent to evaluate allimpacts that the mine may have on the health ofpeople of Fermont and Newfoundland.I do not want to look out my window at a plant.You’re mining in Labrador, but most of the negativeimpacts are going to be on the Fermont side,mainly for dust, noise and visual impact from thewaste stockpile. Are the requirements for dust,noise, etc… different in NL than in Québec?What will I see from my home?Concern that the Project will create visualpollution. Desire to preserve untouched visualaesthetic in Fermont.For the visual aesthetics study, two points of viewshould be assessed: one from the Town of Fermontand the view from the top of the hill by the Lacd’Aviault. It is important that this point of view beassessed because a lot of people hike there andthere is a beautiful viewpoint, we would not wantit to be compromised by the waste rock pile.Will the mine manage the site in a manner thatmakes it not visible from Fermont?Concern that other lakes will become similar toWabush Lake and have same visual impact issue.Will there be any visible impacts resulting from theProjects in the Duley Lake Park area, such as trucksdriving around or waste rock piles?Power lines are a visual issue.Response / Location in EISThe assessment and evaluation of cumulativeenvironmental effects resulting from the Projectin combination with other developments is animportant and integral part of this EIS.The cumulative effects of the Project incombination with other developments on Healthand Community Health are assessed and evaluatedin Section 25.7.\Existing knowledge on the known effects of otherpast projects and activities has been reviewedand has informed the environmental effectsassessment. The VEC analysis considers theseissues and effects.The community of Fermont, as well as LabradorCity and Wabush, are considered within the studyarea (LSA) that has been established for this VECand its effects assessment. See Section 25.2.The possible visibility of Project components fromnearby communities, cabins and other recreationalareas has been a key consideration in Projectplanning and the EA.Viewshed analyses and before and afterphotosimulations of the Project from select vantagepoints have been included in the EIS. These showthat the Project will be minimally visible from thethree municipalities. The Project will be visible fromsome cabin locations.See Section 23.6.4 for the viewshed analysis andphotosimulations.Noise, dust and other such disturbances aremodeled and assessed in Chapter 14, based onapplicable standards in the relevant jurisdiction.The results of each of these VEC analyses havebeen integrated into and informed the assessmentfor Health and Community Health as presented inChapter 25.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 145

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryIssuePotential Effects onSafetyHuman HealthPotential on Qualityof LifeCommunityCabin OwnersFermontWabush /Fermont / LabCityFermontLe mouvementcitoyen deFermontFermontLab West Statusof WomenFermontMatimekush -Lac JohnSummary of comments raised duringconsultation and engagement activitiesAn important issue to me is safety. Safety for cabinowners using Mills Lake access road. No escorts ofsignage for heavy machinery. No safety officer onsite.An important issue to me is that Duncread is beingused and abused and I am concerned about safetywith regards to speed and the number of trucksusing the road.What will be the safety perimeter around the pit toensure people safety?Concerns about safety include child safety dueto increased road and rail traffic, elderly peopleduring construction.At the Mount Wright Arcelor Mittal mine, there isa required evacuation of all personnel for a 1,000metre area when blasting occurs. There may beissues associated with communication regardingblasting to ensure no one is in the area.Is the well-being of the people of Fermont takeninto consideration?Potential impacts from the Kami project on humanhealth. There are currently a number of humanhealth issues as a result of mining in Labrador City.Blood filtration is required by many in LabradorCity as a result of high concentrations of iron. WillAlderon be engaged in the future to treat peoplewith health issues?Possible risks associated with the Project includinghealth risks (increase in levels of iron in the blood,requiring blood filtration)The main issues included drug use (drug testingshould be done when new hire or accidents), anddomestic violence and sexual abuse. They did astudy on impact of mining on women's health,which is available on Mining Watch, and theyfound that mining had no major effect on women'shealth.IOC developed a code of conduct to avoid someissues associated with increased presence of menin the community.Will measures be taken to minimize the impacts oneveryday life (e.g. dust)?Deterioration of community infrastructure andhousing in Matimekush - Lac John is also having anegative impact on quality of life.Drug treatment program is needed to supportpotential workers.Response / Location in EISPotential public health and safety issues areassessed throughout Chapter 25. This includesanalysis and mitigation related to each of the issuesraised, including road and rail traffic, presence anduse of machinery, etc.Safety is a number one concern for Alderon, and allemployees, contractors (including truck operators)are required to comply with Alderon’s Health andSafety Policy and procedures.Potential effects and mitigation related to OtherLand and Resource Users are assessed inChapter 23.Following EA approval, a Blasting Plan will bedeveloped and implemented in compliancewith all applicable laws, regulations and industrybest practices, and with consideration of safety,environmental and social issues, as identifiedthrough the EA. See Section 2.6.2.The community of Fermont is considered within thestudy area (LSA) that has been established for theHealth and Community Health VEC and its effectsassessment. See Section 25.2.The potential for Project related emissions tointeract with and affect the health of humans hasbeen assessed in Chapter 25, and through theassociated HHRA. This includes the potential forissues related to iron concentrations in humans.Alderon’s commitments to mitigation are alsooutlined in Section 25.6.These and other social/community health issuesare assessed within the Community Health aspectof Chapter 25, including associated mitigationmeasures to avoid or reduce any such effects.Existing knowledge on the known effects of otherpast projects and activities has been reviewedand has informed the environmental effectsassessment. Additional information is provided inSections 25.5; 25.6; 25.7; 25.9.Alderon will provide employee assistance andsupport programs for its workforce, as described inSection 25.6.2.Potential effects and mitigation related to dustissues are assessed in Chapter 14 and elsewhere.This includes commitments to various dustsuppression and management measures.The potential implications of the Project forhousing and other services and infrastructure inLabrador and Québec are assessed in Chapter24 (Community Services and Infrastructure).The Project is not expected to have an effecton community infrastructure and housing inMatimekush - Lac John.Alderon will provide employee assistance andsupport programs for its workforce, as described inSection 25.6.2.B – 146

IssuePotential on Qualityof Life(continued)CommunityWabushWabush /FermontLab CityFermontCIM ConferenceSummary of comments raised duringconsultation and engagement activitiesConcern of location of transmission line (magneticfield, noise) and health issues for those who live inone mile proximity.Concern of social impacts for fly in-fly outoperations including sexual harassment of womenWhat will be the human health impacts in Fermontresulting from location of the waste pile. Mainconcern is the impact to quality of life. What willbe the impacts from toxic plumes associated withblasting, and contamination of the water supply?In other mining projects, seeding was done onwaste rocks. Levels of iron in blood are high in thepopulation. Their blood must be filtered.It has been hard to preserve the quality of life,services and infrastructure in the community andwe hope it is not affected by the Kami Project.Domestic violence and drug abuse.Worried about the effects of blasting andassociated noise on the community. Communitymembers can hear / feel blasting from other mines(Arcelor Mittal mine, IOC) and the Rose Pit is muchcloser. How could it be possible not to be affectedby your mine?You’re mining in Labrador, but most of the negativeimpacts are going to be on the Fermont side,mainly for dust, noise and visual impact from thewaste stockpile.Are the requirements for dust, noise, etc…different in NL than in Québec?Response / Location in EISThe potential for Project related emissions tointeract with and affect the health of humans hasbeen assessed in Chapter 25, and through theassociated HHRA.The Project power requirements and the mannerin which they will be addressed (options) aredescribed in Section 2.5.6, including responsibilityfor permitting and constructing any newtransmission line(s).The design and construction of the transmissionline will be in compliance with all applicableregulatory standards. Key considerations in thedesign and planning of the transmission line aredescribed in Section 2.5.6.Identifying and avoiding any such issues has beena key part of Project planning. These and othersocial / community health issues are assessedwithin the Community Health aspect of Chapter 25,including associated mitigation measures to avoidor reduce any such effects. This includes engagingwith government agencies and municipalitiesto establish a Project accommodation strategyand implementing other measures such as workrotations and transportation of non-residentworkers.The potential for Project related emissions tointeract with and affect the health of humans hasbeen assessed in Chapter 25, and through theassociated HHRA.Visual aesthetics issues (including viewshedmodeling) is addressed in detail in Chapter 23of the EIS. Refer to Section 23.6.4. The originallocation of the waste rock disposal facility waschanged following consultation and concerns raisedby the residents of Fermont.Re-vegetation, progressive rehabilitation, and othermeasures will also be implemented.These and other social/community health issuesare assessed within the Community Health aspectof Chapter 25, including associated mitigationmeasures to avoid or reduce any such effects.The potential implications of the Project forhousing and other services and infrastructure inLabrador and Québec are assessed in Section 24.6.A Blasting Plan will be developed and implemented.See Section 2.6.2.Detailed modeling and analysis of the noise andvibration associated with Project construction andoperations is provided in Chapter 14.The community of Fermont is considered within thestudy area (LSA) that has been established for thisVEC and its effects assessment. See Section 25.2.Detailed modeling and analysis of the dust,noise and visual issues associated with Projectconstruction and operations is provided in Chapters14 and 23, including (where relevant) an evaluationof these effects against existing regulations andstandards.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 147

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryIssuePotential on Qualityof Life(continued)CommunityLabrador City /Wabush / LabCityCabin OwnersInnu NationSummary of comments raised duringconsultation and engagement activitiesConcern that dust will affect the quality of life, anduse of recreation areas. Cabin owners particularlyconcerned with this issue. Suggestion to relocatetailings to south.Cabin owners along the east side of the propertyare complaining about low level helicopter flying.Concern that there are too many helicopters andassociated noise impacts, including early morningflyovers of cabin properties. Sling load loss fromhelicopter in area of a cabin (remote location).If I can hear / see / smell the project am I affectedand how will I be treated?Requesting that the company take the sameenvironmental and ethical activities towards allmunicipalities surrounding the project.Suggested that Alderon should consider such aprogram where all community members over theage of 60 are provided with a monthly allowanceof 600$. A similar program for the Voisey's BayProject has been very helpful for the community.When we choose to live in Fermont, it is thetranquility and nature surrounding us that makeus stay here. It is unfortunate that economicdevelopment is done to the disadvantage of thepopulation living on the territory.Concerned about potential environmental andsocio-economic effects in Fermont, such asrecreational activities in Fermont, air quality, noiseand quality of life.Response / Location in EISDetailed modeling and analysis of the dust,noise and visual issues associated with Projectconstruction and operations is provided in Chapters14 and 23, including (where relevant) an evaluationof these effects against existing regulations andstandards.The proposed TMF is located west of Riordan Lakein the eastern portion of the Project area. SeeFigure 2.5 in Section 2.5 for an overall site plan.Key considerations in the design and planning ofthe TMF are described in Section 2.5.4 and 2.6.2.Various alternatives were identified and evaluatedbased on technical, economic and environmentalfactors, as described in Section 2.8.Detailed modeling and analysis of the dust,noise and visual issues associated with Projectconstruction and operations is provided in Chapter14 and elsewhere in this EIS, including the potentialimplications of these for land and resource use inthe area (Chapter 23).The communities of Wabush, Labrador City andFermont are each included within the study area(LSA) that has been established for this VEC and itseffects assessment. See Section 25.2.Alderon will adhere to the provisions included inany benefits agreement signed in relation to theProject. Alderon’s current Aboriginal engagementprocesses are described in Chapter 10, and itsAboriginal Relations Policy is outlined in Section1.1.1.The community of Fermont is considered within thestudy area (LSA) that has been established for thisVEC and its effects assessment. See Section 25.2.B – 148

Table B.14Issues Raised by Aboriginal Groups and Stakeholders – Economy, Employment and BusinessIssueAboriginalEmploymentand BusinessOpportunitiesCommunityInnu NationInnu ofMatimekush-LacJohnNNKInnu of Uashatmak Mani-UtenamNCCInnu BusinessDevelopmentCentreNNKSummary of comments raised duringconsultation and engagement activitiesAlderon should organize a site tour for elders anda few students from local schools to promoteemployment.Do not like when agreements are in place andpeople forget about implementation. For example,training was not done for Voisey’s Bay as detailedin the agreements. Contracts were only awardedto big companies and not evenly shared withsmaller companies.Request for breakdown of employment andbusiness opportunities for the winter 2012 drillingprogram.Request for environmental monitors on theProject.A drug treatment program is needed to supportpotential workers.Want to be kept informed of business andcontracting opportunities. Interested in economicopportunities, and have a mining explorationtraining group and an environmental assessmenttraining group. Have also started vocationaltraining for trades, and by the constructionphase should have people in training. Have awaste management company and could pick upthe waste produced by mine dispose of it (e.g.tires). Also looking to open a contaminated soiltreatment centre in Schefferville, which would becloser and cheaper than the current one in BaieComeau.Has agreements with many partners and wantmembers of the community to benefit fromthese projects. Also have many companies inthe community and want them to benefit fromprojects.Are there opportunities available for NCC to getinvolved in baseline study work? Interested inbusiness opportunities associated with the Project,for example they could potentially support drillingactivities.Inquiry about employment opportunities for twoAboriginal community members who recentlycompleted their online drilling training programs.What benefits will the Naskapi receive from thisProject?Response / Location in EISAlderon is committed to building mutuallybeneficial and respectful relationships with allAboriginal groups. Alderon’s current Aboriginalengagement processes are described in Chapter10, and its Aboriginal Relations Policy is outlined inSection 1.1.1.Alderon is committed to building mutuallybeneficial and respectful relationships with allAboriginal groups. Alderon’s current Aboriginalengagement processes are described in Chapter10, and its Aboriginal Relations Policy is outlined inSection 1.1.1. The Project Benefits Plan, DiversityPlan and any Benefits Agreements will addressthese issues. Alderon is currently negotiating abenefits agreement with Innu Nation. Additionalinformation is available in Chapter 26.Alderon provided Innu Nation with this informationin November 2011 (Section 10.3).A Project-specific EPP will be developed prior tostart of the construction phase. Alderon will havean on-site Environmental Monitor whose duties willinclude inspection of worksites and activities forconformance with the EPP, application of mitigationmeasures required by design, and compliance withgovernment regulations and permits. See Chapter 8for more informationAlderon will provide employee assistance andsupport programs for its workforce, as described inSection 25.6.2.Alderon will develop a Project Benefits Planand Diversity Plan that includes a wide range ofeffects management mechanisms and initiativesdesigned to enhance the benefits to the Provinceof Newfoundland and Labrador, and especiallyLabrador and Economic Zone 2, and to women,Aboriginal people and persons with disabilitiesresident in the Province. Additional information isfound in Section 26.6.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 149

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryIssueApprenticeship andTrainingAvailability of LocalWorkersCommunityCollege of theNorth AtlanticLabrador CityHyron RegionalEconomicDevelopmentBoardProvincialAdvisory Councilon the Status ofWomen (PACSW)College of theNorth AtlanticInnu NationLab West Statusof WomenInnu NationLabrador City/ Wabush /FermontLabrador CitySummary of comments raised duringconsultation and engagement activitiesWants to advance the Aboriginal file and providetraining opportunities.Alderon should actively participate in journeyman/ apprenticeship programs.Apprenticeship and training: there should beindustry-led initiatives. Industry needs to beinvolved to solve these issues.It is important to set targets. The numberspresented by Alderon are great at this stagebecause it may help women decide in which lineof work they can train to get employment in theProvince.Issue with women in trades, apprenticeships.There is also an issue with women in technologyprograms where there are no apprenticeships, itis hard to find work. Need to communicate withindustry.CNA would like to know Alderon’s diversity targets.1:4 ratio of apprentices for journeypersons. Scarcejourneypersons and challenge to grow apprenticesto journeypersons. IOC and Hebron have peakemployment at similar point in time as Alderon soit will be a challenge for the Province to have localworkforce. Alderon should start recruitment andtraining of workers by Fall 2012. Should meet againto continue discussion.Alderon could contribute in the community byproviding training opportunities. Suggested thata mentorship / training program in place forenvironmental monitors. There was a Guardianprogram in Innu Nation in the past, that was veryuseful in training people as it is not within theregular school system.Main issues include apprentices.Alderon should organize a site tour in the newyear for Innu Nation elders and a few studentsfrom local schools to promote employment. Alsosuggested that Alderon provide scholarships forstudents.How many people will be needed for the mine?How many permanent workers will there be andwhat is the plan to attract workers?Will preference be given to local workers? Willworkers from Québec be recruited?Do you need any surveyors?Complaints from trades people who cannot obtainemployment from local companies. Resentmentof workers brought in for jobs that can be done bylocal population. How many permanent workerswill there be and how will you get them?Response / Location in EISMeetings have been held with CNA and othertraining institutions to discuss Project trainingrequirements. Alderon is committed to theencouragement and assistance of residents of theProvince, and in particular of Labrador, to receivethe education and training necessary to maximizetheir opportunities for employment on and relatedto the Project. Alderon will develop a ProjectBenefits Plan and Diversity Plan that includes awide range of effects management mechanismsand initiatives designed to enhance the benefits tothe Province of Newfoundland and Labrador, andespecially Labrador and Economic Zone 2. This isdiscussed in Section 26.6.1.2 and Chapter 24.Alderon is committed to building mutuallybeneficial and respectful relationships with allAboriginal groups. Alderon’s current Aboriginalengagement processes are described in Chapter10, and its Aboriginal Relations Policy is outlined inSection 1.1.1.Alderon will develop a Project Benefits Planand Diversity Plan that includes a wide range ofeffects management mechanisms and initiativesdesigned to enhance the benefits to the Provinceof Newfoundland and Labrador, and especiallyLabrador and Economic Zone 2, and to women,Aboriginal people and persons with disabilitiesresident in the Province. Additional information isfound in Section 26.6. .Alderon will focus on increasing opportunities forresidents of western Labrador, Labrador as a whole,and the rest of the Province. Employment-relatedand business-related actions include advertisingopportunities locally through print media, websitesand Project website and working with Labradorstakeholders to identify how best to involveLabrador businesses in the Project. Additionalinformation is found in Section 26.6.B – 150

IssueAvailability of LocalWorkers(continued)Business AccessDiversity in theWorkplaceCommunityCIM ConferenceLabrador CityWabushProvincialAdvisory Councilon the Status ofWomen (PACSW)Newfoundlandand LabradorOrganizationof WomenEntrepreneursFermontLab West Statusof WomenSummary of comments raised duringconsultation and engagement activitiesAre you going to use local workers for operationsor go FIFO?Will Alderon have administration and humanresources in Lab West or in Montreal?When will Alderon be hiring someone local forcommunity relations?IOC and Hebron have peak employment at similarpoint in time as Alderon so it will be a challenge forthe Province to have local workforce.Alderon should start recruitment and training ofworkers by Fall 2012.Should meet again to continue discussion.Alderon should educate business ownersthrough supplier development sessions to ensuredevelopment of local suppliers.Develop business access strategy, especially forwomen-owned businesses.They mentioned that women in business couldhave a great positive community impact. Supplierdiversity and set targets for women ownedbusinesses.Concern that job opportunities will only be forAnglophones.Can equality program also include opportunitiesfor female Francophones?The main issues include women in trades, andadapting to women in the workplace and havingpolicies for respectful workplace.College of North What are Alderon's diversity targets in theAtlantic workplace?ProvincialAdvisory CouncilDiversity in the workplace is an important issueon the Status ofWomen (PACSW)NLOWEAlderon should educate business ownersthrough supplier development sessions to ensuredevelopment of local suppliers. Develop businessaccess strategy, especially for women-ownedbusinesses. Women in business could have a greatpositive community impact. Supplier diversity andset targets for women owned businesses.Response / Location in EISAlderon is engaging with government agenciesand municipalities to establish a Projectaccommodation strategy. Alderon will consideremploying a Fly-in / Fly-out workforce duringthe construction phase of the Project. Duringoperations and maintenance, Alderon aims to hirea residential workforce. Additional information isfound in Sections 24.5, 24.6, 26.5 and 26.6.Alderon will have administration and humanresources staff in western Labrador. A list ofoccupations by NOC code is found in Chapter 2.Alderon will focus on increasing opportunities forresidents of western Labrador, Labrador as a whole,and the rest of the Province. Employment-relatedactions include advertising opportunities locallythrough print media, websites and Project websiteand working with Labrador stakeholders to identifyhow best to involve Labrador residents in theProject. Additional information is found in Section26.6.Alderon will work with the provincial Skills TaskForce and other industry and professional groups,trades unions, training institutions and othermining companies to address current and futurelabour shortages. Alderon will also work withthese groups to facilitate the delivery of trainingto Labradorians and Newfoundlanders, includingmembers of the designated groups. Additionalinformation is available in Section 26.6.Alderon will develop a Project Benefits Planand Diversity Plan that includes a wide range ofeffects management mechanisms and initiativesdesigned to enhance the benefits to the Provinceof Newfoundland and Labrador, and especiallyLabrador and Economic Zone 2, and to women,Aboriginal people and persons with disabilitiesresident in the Province. Additional information isavailable in Section 26.6.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 151

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryIssueFinancial Benefit forMunicipalityPotential Effects onLocal BusinessesCommunityWabushCIM ConferenceSept-ÎlesFermontWabushSummary of comments raised duringconsultation and engagement activitiesComment that Bloom Lake project has not lived upto commitments in Lab West.Work with stakeholders to give something back tothe community.Do not want to pit ourselves against Labrador Cityor others, but if we (Wabush) are to be impactedmore, we expect more of the benefits.Many indications of interest by regional suppliersand contractors. In this regards, I believe we shouldhold information forums in St. John’s and Sept-Îleswhen our contracting strategy is firmed up.Involvement of the local communities andbusinesses in the procurement process for theconstruction and operation of the mine.State the company’s intentions concerning localprocurement.Commercial camp owner on Lake Daviault isconcerned about dust, visual, noise, moneyinvested on developing site.What will be the economic spin-offs for Fermont?Will it be Fly-in / Fly-out? Will you build houses?Owners of the Duley Lake park will probably notwant the Project to impact their businessResponse / Location in EISThe follow-up and monitoring policies andpractices for all Project phases will be as specifiedin the Benefits and Diversity Plan. They providea description of Alderon’s process for monitoringand reporting benefits and diversity performance,including success in meeting quantitative and othertargets, based on its own performance and thatof its contractors and sub-contractors. Additionalinformation is found in Sections 26.6 and 26.11.Alderon is committed to working with communitystakeholders throughout the EA and the life of theProject to maximize benefits for the community.The Benefits and Diversity Plan will outlineAlderon’s commitment to optimize local benefits.Additional information is found in Section 26.6,as well as in Chapter 24: Community Services andInfrastructure.The Project Benefits and Diversity Plan will outlineAlderon’s commitment to working with localbusiness. Alderon will hold information sessions forsuppliers, packaging bids so local companies arecontenders. More information is found inSection 26.6.The Project Benefits Plan will outline Alderon’scommitment to working with local business.Alderon will hold information sessions for suppliers,packaging bids so local companies are contenders.More information is found in Section 26.6.The potential Project effects on cabin use areincluded in the assessment of the Project on OtherUse of Lands and Resources. Alderon has beenengaging with cabin owners in the Project areaand has developed a strategy to mitigate adverseeffects on cabin owners. Alderon will continueits engagement with cabin owners to determineappropriate mitigation for individual cabin owners,as applicable.See Sections 23.5.2.1 and 23.6.3.The effects of the Project on Economy, Employmentand Business in Fermont are assessed in Chapter26.. Alderon will consider employing a fly-in/flyoutworkforce during the construction phase ofthe Project. During operations and maintenance,Alderon aims to hire a residential workforce.Additional information is found in Section 26.6.Potential effects on Duley Lake Provincial Park fromthe Project have been assessed and mitigationmeasures identified. More details about the resultsof this assessment are provided in Sections 23.6and 24.6.B – 152

IssuePotential Effects onLocal EconomyCommunityCabin OwnersWabushLabrador CityLabrador CitySept-ÎlesWabushFermontLe mouvementcitoyen deFermontSummary of comments raised duringconsultation and engagement activitiesAn important issue is the impact on the localeconomy. Please use local people no "fly in, flyout" stuff.Is Alderon going to build a new town site or leavethe requirement for 600-700 employees up to theeconomy to provide - local contractors, etc.?Will Alderon be hiring locals as a priority?Will Alderon be promoting that workers live in LabWest?At the end of the predicted mine life, what are yougoing to do with your employees?Concern about economic impacts on cities.Concern about economic impacts to local campsites, cabins and parks.When we choose to live in Fermont, it is thetranquility and nature surrounding us that makeus stay here. It is unfortunate that economicdevelopment is done to the disadvantage of thepopulation living on the territory. Concerned thatAlderon is presenting the project as a positive forthe community.What impact will the mine have on tourism giventhe importance to the local economy?Response / Location in EISAlderon will consider employing a fly-in/fly-outworkforce during the construction phase of theProject. During operations and maintenance,Alderon aims to hire a residential workforce.Alderon will develop a Project Benefits Planand Diversity Plan that includes a wide range ofeffects management mechanisms and initiativesdesigned to enhance the benefits to the Provinceof Newfoundland and Labrador, and especiallyLabrador and Economic Zone 2, and to women,Aboriginal people and persons with disabilitiesresident in the Province. Additional information isfound in Section 26.6.The work force will be kept informed of Projectplans and, as with any other project, will be downsizedas the Project plans warrant.An assessment of the economic effects of theProject on Labrador City, Wabush and Fermont ispresented in Chapter 26.The potential Project effects on cabin use, andrecreational sites are included in the EIS as partof the assessment of the effects on Other Useof Lands and Resources. Economic effects of theProject on the tourism industry are also assessed.Alderon has been engaging with cabin owners inthe Project area and has developed a strategy tomitigate adverse effects on cabin owners. Alderonwill continue its engagement with cabin ownersto determine appropriate mitigation for individualcabin owners, as applicable. See Section 23.5.2 and23.6 for additional information.The purpose of the EA process is to identifymitigation measures to avoid or reduceenvironmental issues and effects. These aredescribed throughout this EIS, and summarized inChapter 27. Alderon has presented informationabout the Project and potential effects to thecommunity, and responded to public concernsand questions throughout the EA process, andwill continue to do so throughout the life of theProject. Information about Alderon’s consultationand engagement activities completed to date areincluded in Chapter 10.Potential effects of the Project on the localeconomy, including the tourism sector are assessedand mitigation identified in Section 26.6.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 153

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary10 Fort William Place, 8th FloorSt. John’s, NL A1C 5W2B – 154Tel: (709) 576-5607Fax: (709) 576-7541

KAMI CONCENTRATE STORAGE& LOAD-OUT FACILITY,QuébecKami Iron Ore ProjectEnvironmental Impact StatementAlderon Iron Ore Corp.10 Fort William Place, 8 th FloorSt. John’s, NL A1C 5W2Tel: (709) 576-5607Fax: (709) 576-7541Kami Concentrate Storageand Load-Out Facility, QuébecPlain Language SummaryPrepared byStassinu Stantec Limited PartnershipKami Iron Ore ProjectEnvironmental Impact StatementPLAIN LANGUAGE SUMMARY September 2012

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryKami Iron Ore Project.a summary of theenvironmental impact statementii

ForewordThis document is intended to be a non-technical summary of theEnvironmental Impact Statement (EIS) for the Kami ConcentrateStorage and Load-out Facility (Kami Terminal) in Sept-Îles, Québecproposed by Alderon Iron Ore Corp (Alderon). The purpose of thisdocument is to provide an overview of key findings of the EIS withrespect to potential environmental effects as well as commitmentsto managing those effects to acceptable levels over the life ofthe Project. This document is intended to support Aboriginalengagement and public consultation and is available in English andFrench. Readers are encouraged to review the full EIS document foradditional details on the assessment.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryPrinted on EarthChoice® (Rainforest Alliance Certified and FSC Certified) Paperiii

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summaryiv

Table of Contents1.0 INTRODUCTION.................................................................................................................................................. 11.1 Project Overview....................................................................................................................................... 11.2 Environmental Assessment Process.......................................................................................................... 41.2.1 Purpose of the EIS....................................................................................................................... 41.2.2 Federal Requirements................................................................................................................. 41.2.3 Provincial Requirements............................................................................................................. 51.2.4 Cooperative EA Process.............................................................................................................. 52.0 PROJECT DESCRIPTION...................................................................................................................................... 62.1 Purpose of and Need for the Project........................................................................................................ 62.2 Project Description................................................................................................................................... 62.2.1 Location...................................................................................................................................... 62.2.2 Components............................................................................................................................... 62.2.3 Activities..................................................................................................................................... 72.2.4 Schedule..................................................................................................................................... 82.2.5 Labour Force Requirements........................................................................................................ 83.0 SCOPE OF THE ASSESSMENT............................................................................................................................. 93.1 Scope of the Project.................................................................................................................................. 93.2 Factors to be Considered.......................................................................................................................... 93.3 Scope of the Factors.................................................................................................................................. 93.3.1 Identification of VECs................................................................................................................ 103.3.2 Spatial and Temporal Boundaries............................................................................................. 114.0 PROJECT ALTERNATIVES.................................................................................................................................. 124.1 Alternatives to the Project...................................................................................................................... 124.2 Alternative Means of Carrying out the Project.......................................................................................125.0 CONSULTATION................................................................................................................................................. 155.1 Public and Aboriginal Consultation and Engagement Activities undertaken for the EA.........................156.0 EXISTING ENVIRONMENT................................................................................................................................ 217.0 ENVIRONMENTAL EFFECTS ASSESSMENT...................................................................................................... 237.1 Method and Approach............................................................................................................................ 237.2 Valued Ecosystem Components.............................................................................................................. 267.2.1 Atmospheric Environment........................................................................................................ 267.2.2 Landforms, Soils, Snow and Ice................................................................................................ 297.2.3 Water Resources....................................................................................................................... 307.2.4 Wetlands................................................................................................................................... 327.2.5 Freshwater Fish, Fish Habitat and Fisheries.............................................................................. 327.2.6 Birds, Other Wildlife and Their Habitats and Protected Areas................................................. 337.2.7 Species at Risk and Species of Conservation Concern.............................................................. 357.2.8 Historic and Cultural Resources................................................................................................ 367.2.9 Current Use of Lands and Resources for Traditional Purposes by Aboriginal Persons..............387.2.10 Other Current Use of Lands and Resources.............................................................................. 407.2.11 Community Services and Infrastructure................................................................................... 427.2.12 Health and Community Health................................................................................................. 447.2.13 Economy, Employment and Business....................................................................................... 447.3 Effects of the Environment on the Project.............................................................................................. 477.3.1 Method and Approach.............................................................................................................. 477.3.2 Issues........................................................................................................................................ 477.3.3 Potential Environmental Effects................................................................................................ 477.3.4 Mitigation Measures................................................................................................................. 477.3.5 Residual Environmental Effects................................................................................................. 48Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summaryv

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary7.4 Effects of Possible Accidents or Malfunctions.........................................................................................487.4.1 Method and Approach.............................................................................................................. 487.4.2 Issues........................................................................................................................................ 487.4.3 Potential Environmental Effects................................................................................................ 487.4.4 Residual Effects......................................................................................................................... 497.5 Effects on Capacity of Renewable Resources..........................................................................................507.6 Cumulative Environmental Effects.......................................................................................................... 507.6.1 Approach.................................................................................................................................. 507.6.2 Scoping..................................................................................................................................... 507.6.3 Issues........................................................................................................................................ 507.6.4 Potential Cumulative Effects..................................................................................................... 517.6.5 Mitigation Measures................................................................................................................. 517.6.6 Residual Effects......................................................................................................................... 518.0 FOLLOW-UP PROGRAM................................................................................................................................... 529.0 BENEFITS OF THE ENVIRONMENTAL ASSESSMENT TO CANADIANS........................................................... 5410.0 OVERALL CONCLUSIONS OF THE PROPONENT.............................................................................................. 5511.0 REFERENCES..................................................................................................................................................... 56APPENDIX A:VEC Summary Tables and Residual Effects Summary Matrices.................................................................................... 57APPENDIX BComplete Record of all Comments Identified During Consultation and Engagement Activities with Responses........75vi

1.0 INTRODUCTIONAlderon Iron Ore Corp. (Alderon) is proposing to develop and operate an iron oremine on the Kamistiatusset (Kami) Property in western Labrador, which will have anominal capacity of 16 million metric tonnes of iron ore concentrate each year thatwill be transported by existing rail lines to the Pointe-Noire Terminal that is part ofthe Port of Sept-Îles, Québec (the Project).Alderon is committed to taking a responsible approach to social, economicand environmental performance that is consistent with the priorities of ourstakeholders. Alderon’s goal is to build and maintain positive and long-termrelationships with stakeholders of the proposed Project.Alderon is committed to building relationships, based on mutual trust and respectand collaborating with Aboriginal groups that may be affected by the Project andthat have asserted or established Aboriginal rights, Aboriginal title or treaty rightsor whose traditional land and resource use activities may be affected bythe Project.This document describes the environmental effects of the Kami ConcentrateStorage and Load-out facility that Alderon proposes to build at the Port of Sept-Îles(Kami Terminal). A separate summary document has been prepared to describeAlderon’s proposed mines and facilities in western Labrador (Kami Mine).1.1 Project OverviewAlderon is proposing to develop an iron ore mine on the Kami Property locatedin western Labrador. The mine property is located south of the towns of Wabushand Labrador City in Newfoundland and Labrador and east of Fermont, Québec.The Kami Iron Ore Mine and Rail is located entirely within Labrador. The mine willproduce a nominal capacity of 16 million metric tonnes of iron ore concentrate peryear. Concentrate will be transported byexisting rail to the Kami Terminal whereAlderon’s goal is to build andmaintain positive and long termrelationships with stakeholdersof the proposed Kami Project.the concentrate unloading, stacking,storage and reclaiming facility, andassociated rail infrastructure will belocated on land within the jurisdictionof the Sept-Îles Port Authority.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary1

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary±TshiuetinRailwayLabrador CityFermontU n g a v a B a y!!^_!ScheffervilleWabushSmallwood Reservoir!!Churchill FallsNain!Natuashish!!Hopedale!!Postville!Sheshatshiu^_RigoletHappy Valley-Goose Bay!Sept-ÎlesTerminal SiteA T L A N T I CO C E A NCartwright!CharlottetownKamiMine Site!ForteauQuebec North Shoreand Labrador Railway!^_Sept ÎlesTerminal SiteG u l f o f S t . L a w r e n c eFIGURE ID : ALD_ST_6970 50 100Kilometres2

Kami Iron Ore Project General Location±FIGURE ID: ALD_ST_7030 2 4The Kami Terminal consists of a rail loop and a concentrate unloading, stacking,storage, and reclaiming facility designed to store and transport the ore beforeshipping it to market.Arnaud CompanyRailwayExistingConveyorBaie des Sept-Îles^_Port of Sept-Îles PropertyTerminal SiteGolfe du St - LaurentÎle ManowinÎleGrandeBasqueSept-ÎlesQuébec North Shoreand Labrador RailwayQUÉBECÎlePetiteBouleKamistiatussetMine Site^_^_Terminal SiteATLANTICOCEANLABRADORKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryKilometresÎle Corossol3

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary1.2 Environmental Assessment Process1.2.1 Purpose of the EISThe submission of the Environmental Impact Statement (EIS) is an important stepin the environmental assessment review process. The EIS is a careful and detailedconsideration of how the Kami Terminal could affect the residents, communities,and natural environment surrounding the site. The EIS addresses the issues raisedby regulators, the public and Aboriginal through Alderon’s public consultationprocess. The EIS will be reviewed by the EA Committee, including subject areaexperts from government and regulatory agencies and is available for publicreview. Review comments of the EA Committee and thepublic will be considered when a determination of theenvironmental implications of the Project is made by thefederal and provincial governments.The EIS consists of a Plain Language Summary, anExecutive Summary, Volume 1 (Kami Iron Ore Mine andRail Infrastructure) and Volume 2 (Kami ConcentrateStorage and Load-out Facility).1.2.2 Federal RequirementsFederal approvals will be required from:• Fisheries and Oceans Canada (DFO) (Fisheries Act);• Transport Canada (Navigable Waters Protection Act);• Natural Resources Canada (Explosives Act); and• Canadian Transportation Agency(Canada Transportation Act).Under CEAA, a “comprehensive study” level of assessmentwill be required since the Kami mine will have an “iron orecapacity of 3,000 t/d or more”.An environmentalassessment is a decisionmakingtool used topromote sustainabledevelopment byevaluating the potentialenvironmentaleffects of majordevelopments beforethey are constructed.This process involvesvarious governmentagencies as well aspublic, stakeholder andAboriginal consultationand engagement.4

1.2.3 Provincial RequirementsBecause the mine will be located entirely within Newfoundland and Labrador,and the facilities at the Port of Sept-Îles will be located on federal lands, the KamiTerminal is not subject to an environmental assessment under the laws of theprovince of Québec, as confirmed by the ministère du Développement durable,de l’Environnement et des Parcs (MDDEP). However, Alderon has committed tomaintaining continued communication with MDDEP to ensure that updates andinformation is provided on an ongoing basis.1.2.4 Cooperative EA ProcessThe Kami Iron Ore Mine and Rail Infrastructure will require approvals fromprovincial and federal governments, including environmental assessmentapproval under the Newfoundland and Labrador Environmental Protection Actand federal Canadian Environmental Assessment Act (CEAA). Both governmentsare working together to use one environmental assessment to satisfy theirrespective regulatory requirements. An environmental assessment is a decisionmakingtool used to promote sustainable development by evaluating the potentialenvironmental effects of major developments before they are constructed. Thisprocess involves various government agencies as well as public, stakeholder andAboriginal consultation and engagement.The proposed Kami Terminalis required to allow for thetransportation of the Project’siron ore products to market.Because the facilities at the Port ofSept-Îles will be located on federallands, the Kami Terminal is not subjectto environmental assessment underthe laws of the province of Québec, asconfirmed by the MDDEP.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary5

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary2.0 PROJECT DESCRIPTION2.1 Purpose of and Need for the ProjectThe purpose of the Project is to develop the iron ore deposits located at theKami Mine Property in Labrador, and in doing so, to produce iron ore concentratesuitable for sale to international markets. There is currently a very high levelof demand for iron ore and steel worldwide, which is creating and maintainingrelatively strong markets and good prices for iron and steel.The proposed Kami Terminal, as described in this chapter, is required to allow forthe transportation of the Project’s iron ore products to market, and are thereforevital to the overall technical and economic viability of the Project.2.2 Project Description2.2.1 LocationThe proposed Kami Terminal will be located at the Pointe-Noire Terminal in thePort of Sept-Îles, which is within the region known as the Québec North Shore,along the Gulf of St. Lawrence.2.2.2 ComponentsThe Kami Terminal components and activities will include the construction andoperation of the following key elements:• A concentrate unloading, stacking, storage and reclaiming facility; and• Associated rail infrastructure (rail loop).Concentrate Unloading, Stacking, Storage and Reclaiming FacilityThis facility will be designed to receive iron ore concentrate from Labrador, storeit and then transport it to the ship loader for eventual shipment to markets. Astorage yard will be built measuring approximately 160 m by 340 m in size andwill house two piles of iron ore. The substrate of the yard will contain a liner thatwill act as a barrier to ensure that water from rain and snow (i.e., runoff water) iscollected and treated to prevent red water issues. “Red water” is the term used forwater that contains fine particles of iron oxide / hydroxide.A stacker-reclaimer will be designed to meet yard and ship loading requirements.Supply conveyors will be constructed in the yard to feed concentrate from the railcar dumper to a transfer house and from there to the stacker-reclaimer. The yardwill also include maintenance facilities, offices, and administrative areas.6

Kami Terminal Components±Port of Sept-Îles PropertyExisting ConveyorFIGURE ID: ALD_ST_7040 150 300MetresExisting RailwayConsolidated ThompsonConveyor LineProposed Rail forProject BeginsProposed Port AuthorityCommon Offload PointSwitch YardControl RoomConveyor Line ProposedBy AlderonRe-routed RailwayAlderon Concentrate StockpilesCT StockpileBaie desSept-Îles^_Storm Water RetentionPond andTreatment BuildingRailcar UnloadingBuildingTransmission LineTerminal SiteSept-ÎlesProposed AlderonRail LoopRe-routed AccessRoadStockpile YardRail LoopApproximately 3.5 km of new (single) rail track will be required to connect with theexisting Arnaud Company Railway (Chemin de fer Arnaud – CFA) railway track ata point several hundred meters southwest of the proposed Terminal. The rail willloop around the site of the existing and future expansion of the Cliffs unloadingand concentrate stockpile area. The rail loop will be designed to accommodate aminimum of 120 cars full of iron ore concentrate and will be used exclusively forthe unloading of Alderon iron ore concentrate.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary2.2.3 ActivitiesThe Kami Terminal will involve the construction, operation and eventual closureand decommissioning of each of the components described above.Construction activities for the Kami Terminal will include the following:• Movement of equipment, materials and personnelto, within and from the site;• Mobilization and installation of required construction infrastructure;• Site preparation (including vegetation clearing,grubbing and excavation as required);• Establishing site buildings and other components;• Installation of associated systems, equipment and utilities.The main tasks and general sequencing of the construction phase will include,initially, the transportation of equipment and construction materials to and withinthe site, and the development of lay down areas. Construction lay down areas willbe established at strategic locations near the proposed conveyors, rail loop andelsewhere within the Kami Terminal area / footprint.Operations activities will include offloading of iron ore concentrate from railcars.A rail car dumper will be used to unload the iron ore concentrate from rail cars7

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summaryand conveyor belts will then move the concentrate to the storage yard where itwill be stockpiled by a stacker-reclaimer. The conveyor system will also be usedto transport the concentrate to an ocean vessel shiploader. In addition to thisequipment, a small building will be constructed to store equipment, spare parts,and supplies, and to contain offices for workers.2.2.4 ScheduleConstruction of the Kami Terminal at the Port will begin after the Project hasreceived all the necessary government approvals and permits. The proposedstart date of construction is late 2013 with completion by the end of 2015. TheKami Terminal is expected to begin operating in fall 2015 and continue untilapproximately 2033.Phase/ActivityFeasibility and DetailedEngineeringEA and PermittingConstructionOperations2012 2013 2014 2015 2016 2017 2018 2019 2020-2032Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q4 Q1 Q2 Q3 Q42.2.5 Labour Force RequirementsProjected construction staff numbers will range from approximately 30 to nearly300 workers at the peak periods. Staffing will include construction management,engineering, labourers, millwrights, iron workers, carpenters, heavy equipmentoperators, electricians, masons and other trades as necessary to carry out theconstruction tasks. Most if not all of these positions will be full-time in nature.The phase of construction is expected to occur between approximately late2013 and 2015.2033 2034The operations phase of the Project will commence upon completion ofconstruction and associated commissioning, and is expected to extend fromapproximately 2015 to 2033. Projected operation staff numbers will beapproximately 17 workers, most if not all of which will be full-time employees.8

3.0 SCOPE OF THE ASSESSMENT3.1 Scope of the ProjectThe scope of the Project for the purpose of the environmental assessmentincludes all activities and physical works associated with construction, operation,rehabilitation and closure of the proposed Project.3.2 Factors to be ConsideredThe following factors have been considered as a part of the environmentalassessment:• The need for the Project;• Alternatives to the Project;• The purpose of the Project;• Alternative means of carrying out the Project that aretechnically and economically feasible and the environmentaleffects of any such alternative means;• The environmental effects of the Project, including the environmentaleffects of malfunctions or accidents that may occur in connectionwith the Project and any cumulative environmental effects thatare likely to result from the Project in combination with otherprojects or activities that have been or shall be carried out;• The significance of the environmental effects referenced above;• Comments arising from the public and Aboriginalconsultation and engagement;• Local knowledge and Aboriginal traditional knowledge;• Measures that are technically and economically feasible and that wouldmitigate (lessen) any significant adverse environmental effects of the Project;• The requirements of a follow-up program for the Project;• The capacity of renewable resources that are likely to be significantly affectedby the Project to meet the needs of the present and those of the future.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary3.3 Scope of the FactorsThe assessment of environmental effects focuses on Valued EcosystemComponents (VECs). A VEC is a component or attribute that is important for itsecological, legal, scientific, cultural, economic or aesthetic values.VEC specific factors are discussed in Section 7.9

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary3.3.1 Identification of VECsA total of 13 VECs were identified in the EIS Guidelines for review as a result ofgovernment, Aboriginal persons, stakeholders and general public interests andconcerns. Each VEC is discussed in detail in Section 7.Natural environment VECs are:• Atmospheric Environment (air quality,climate, vibration and noise);• Landforms, Soils, Snow and Ice (landforms,terrain stability, soil quality and quantity,snow and ice as well as the potential for AcidRock Drainage (ARD) and metal leaching);• Water Resources (quality and quantity ofgroundwater and surface water resources);• Wetlands (lands having the water table at, near,or above ground surface, or are saturated longenough to promote wetland aquatic processes);• Freshwater Fish, Fish Habitat, and Fisheries(freshwater fish species and the habitat uponwhich they depend and fisheries activities);• Birds, Other Wildlife and their Habitats,and Protected Areas (migratory and non-migratory speciesthat are potentially feeding, breeding, moving and/or migratingthrough the Project area, their habitat, and Protected Areas);• Species at Risk and Species of Conservation Concern (species of plantor animal, and/or its critical habitat, that is of provincial, national orinternational importance, particularly where the species and/or itscritical habitat is protected under federal or provincial legislation).A VEC is a component orattribute that is importantfor its ecological,legal, scientific,cultural, economic oraesthetic values.10

Human environment VECs are:• Historic and Cultural Resources (archaeological sites, paleontological fossilsites, cultural or spiritual sites and historic buildings and properties);• Current Use of Land and Resources for Traditional Purposes by AboriginalPersons (lands and resources of specific social, cultural or spiritual value tothe Aboriginal persons that are currently used for traditional purposes);• Other Current Use of Lands and Resources (other industrial,residential or commercial uses of the land);• Community Services and Infrastructure (employment,transportation, social , education and health services, safetyand security, and housing and accommodation);• Health and Community Health (human health and wellness and family life);• Economy, Employment, and Business (new economicactivity, workers and local businesses).3.3.2 Spatial and Temporal BoundariesSpatial and temporal boundaries are the study areas and time frames used toinvestigate potential environmental effects of the Kami Terminal.Spatial boundaries are also known as the study area. The spatial boundariesconsider the geographic extent over which the Kami Terminal’s environmentaleffects may occur, recognizing that some environmental effects may extend beyondthe Project Development Area (footprint). Spatial boundaries differ byVEC depending on the nature of predicted effects.Temporal boundaries consider timing and scheduling of Kami Terminal activities,and the time required for recovery from an environmental effect. In general,temporal boundaries for assessment include the construction, operationand maintenance and decommissioning and reclamation phases of the KamiTerminal. For most of the VECs, the temporal boundaries for each Project phaseconsider a construction period of approximately two years, and operation andmaintenance for approximately 17 years. There are currently no intention to closeor decommission the Kami Terminal. Upon conclusion of Alderon operations, theinfrastructure will be transferred (sold) to another owner. The facilities will bemaintained throughout operations with the assumption that it will be operated ona continual basis, even after Alderon has ceased operation.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary11

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary4.0 PROJECT ALTERNATIVESThe EIS Guidelines require consideration of alternatives to the Project andalternative means of carrying out the Project that are technically andeconomically feasible.4.1 Alternatives to the ProjectThe need for and purpose of this Project is to develop the iron ore deposits withinthe Kami Property and to produce iron ore concentrate suitable for saleto international markets.Addressing the overall, worldwide requirement for iron ore could potentially beaddressed through other development projects or initiatives, which may alsoprovide associated economic benefits to the regions and jurisdictions in which theyare developed. With the exception of this proposed Project, however, no othersuch alternatives are within the ability and responsibility of Alderon. The onlyalternative to Alderon’s construction and operation of the Project is a decision tonot proceed with this development – the “no-go” decision.The proposed Project provides a technically feasible, economically viable andattractive, and environmentally and socially responsible means of addressing theidentified need for and purpose of the development and one which can and willbe planned and implemented in a manner that avoids or reduces potential adverseenvironmental effects and optimizes socio-economic benefits.4.2 Alternative Means of Carrying out the ProjectDescription of Alternative MeansThe EA process allows for the identification, analysis, and evaluation of differentproject concepts and approach options and includes environmental considerationsinto project planning at an early stage so it may potentially influence the Projectdesign. The EIS considers possible alternative means of carrying out the Projectthat are technically and economically feasible, and the potential environmentaleffects of any such alternative means. Alderon investigated different port locationsand alternative methods to transport the iron ore concentrate from the Kami Minein Labrador to steel refineries around the world (shown in table below).12

Environmental Effects of Technically and Economically Feasible Alternative MeansProjectComponentLocation of theterminal facilityAlternativeConsideredOption 1: facilitylocated at the Pointe-Noire Terminal thatis part of the Port ofSept-ÎlesOption 2: facilitylocated at Pointe-Noireterminal south-east ofOption 1Option 3: facilitylocated at Seven LandsDevelopment Corp.near mouth of MoisieRiverOption 4: build a newport in LabradorUse existing rail lines at Port of Sept-ÎlesBuild new raillines at Port ofSept-ÎlesOption 1: Work withCliff Bloom Lake tobuild a new rail loopusing some of theirexisting trackOption 2: Build a newrail loop that circlesoutside of Cliff BloomLake rail loopOption 3: Build a newrail loop located westof the Pointe-NoireRoadTransport iron ore concentrate by truckto PortTransport iron concentrate by newrailroad through Labrador and QuébecEconomic & Technical Feasibility• Installation costs are less because located closer to the shiploader• Technically feasible• Port of Sept-Îles is a very active industrial portsite and has been in operation for decades• Moving concentrate a shorter distance could reduceenergy use and the amount of dust released• Little to no loss of habitat• Greater installation costs• Technically feasible• Moving concentrate a longer distance could increaseenergy use and the amount of dust released• Option 3 location has no access to the shore and additionalfacilities would need to be constructed. Not economically feasible.• Technically feasible• Would require construction activity and works in the marineenvironment which would decrease potential marine habitat• Building a new port in Labrador is not economically feasible• Technically feasible• Would require construction activity and works in the marineenvironment which would decrease potential marine habitat• Has economic risk• Dead-end line requires train to be broken down for unloading• Breaking the train cars into smaller sections uses more locomotivefuel, releases higher emissions and creates more noise• Has economic and operational risk• Grading and a stream crossing required• Less economic and operational risks• Grading and a stream crossing required• Costly construction• Landscape would need to be dramatically alteredConstruction would require substantial rock cutting,blasting and other earth-moving efforts• Ruisseau à la Baleine would need to be redirected• Not economically feasible• Shipping goods by truck burns more fuel, releases moreemissions and creates more traffic on the highway• Not economically feasible• Building a new railroad would alter habitat• Construction would require more resourcesthan using already existing rail linePreferredOptionKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummarySelection of a Preferred Alternative MeansThe selected Project components, noted above, were identified as the preferredtechnically and economically preferred option with the least potential for effects tothe environment from Project activities. The environmental effects of the preferredoptions are assessed in the EIS.13

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary14

5.0 CONSULTATION5.1 Public and Aboriginal Consultation andEngagement Activities undertaken for the EASince the acquisition of the Kami Property in Labrador in December 2010, Alderonhas worked to establish open and transparent communication with variouspotentially interested or affected individuals and organizations. Alderon’s approachincludes engagement with Aboriginal groups, public stakeholders and regulatoryagencies. The objectives of this consultation and engagement program wereidentified in accordance with the EIS Guidelines (CEA Agency and DOEC 2012),the Newfoundland and Labrador Environmental Protection Act (NLEPA), and theCanadian Environmental Assessment Act (CEAA).The overall objectives of the consultation and engagement program are to:• Provide Project information and updates on a regular basis;• Engage Aboriginal groups and stakeholders throughout the environmentalassessment (EA) process and during the life of the Project;• Identify issues of concern with the Project early in the process;• Adapt the Project design, where possible, to avoid andmitigate adverse environmental effects; and• Demonstrate how issues and concerns raised duringengagement activities have been addressed in the EIS.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryAlderon’s consultation and engagement program for the EA includes five phasesshown below in an overview of the EA timeline, including associated consultationand engagement phases and program milestones.Timeline for Consultation and Engagement ProgramPre-Project Regitration• Initial informationsharing andrelationship building2011 20122013 OngoingPost-RegitrationProject RegistrationOctober 17, 2011EA Notice of CommencementJanuary 27, 2012• Project informationsessions• Receive comments onthe Project• Identify issuesEIS Pre-Submission• Project information sessions• Receive comments on the Project• Identify issuesEIS SubmissionEIS Post-Submission• Project information sessions• Respond to issues and concernsEA ApprovalPost-EA• Share information and address concernsthroughout the life of the ProjectOngoing Aboriginal Engagement and Public Consultation15

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryPublic and Regulatory Consultation ActivitiesPublic stakeholders engaged by Alderon include residents of the towns ofLabrador City, Wabush, Fermont and Sept-Îles. In addition to stakeholders withinthese boundaries, Alderon has also engaged other potentially affected and/orinterested stakeholders including provincial and federal government agenciesand departments, non-governmental organizations, economic developmentorganizations, and outdoor recreation users and outfitters.Public consultation activities include information sharing, general consultation withcommunity members, and key stakeholder meetings. In particular:• Public notices were created to share information with the generalpublic and those potentially affected by the Project;• A Project website was created to provide Project information, EAdocumentation, notifications, and consultation materials and providedan area for stakeholders to submit contact information and comments;• Public Information Sessions were held to provide information to thegeneral public and other interested stakeholders and receive feedback;• Key stakeholder meetings were held to inform keystakeholders on Project design and EIS studies, and identifyissues with the Project to be included in the EIS.Consultation with federal and provincial regulatory agencies is an importantcomponent of EIS development. Alderon’s approach to regulatory consultation is toestablish and maintain transparent dialogue with federal and provincial regulatorsthroughout development of the EIS. Consultation activities include ongoinginformation updates and meetings, including sharing stakeholder and Aboriginalissues as they arise. In addition, Alderon met with reviewing agencies during thedevelopment of the EIS to present baseline studies, study methodology and effectsassessment for each component chapter. This approach is aimed at informingreviewers, and obtaining feedback early in the process.Issues identified most frequently in relation to the Kami Terminal during public andregulatory consultation include:• Availability of housing for workers;• Water quality;• Dust;• Visual Aesthetics; and• Cumulative effects on community services and infrastructure.16

Frequency of Issues Identified during Public Consultation ActivitiesConsultation / EA ProcessWater ResourcesEconomy, Employment and BusinessCommunity Services and InfrastructureProject Description / RegistrationEA JurisdictionPublic ParticipationAboriginal EngagementProject ScheduleTranslation of Project InformationWaterbodiesWater QualityWater ManagementCumulative Effects onWater ResourcesLocal BusinessesApprenticeship and TrainingAvailability of Local WorkersLocal EconomyCumulative Effects on Economy,Employment and BusinessAvailability of Housing for WorkersCommunity ServicesCumulative Effect on CommunityServices and InfrastructureWildlife Species111111Frequency of Issues2222233333334Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryWildlife, Habitat, and Protected AreasWaterfowl2Parks and Protected Areas1Project Design and LocationEconomic FeasibilityLocation of ConcentrateStorage FacilityAccidents and Malfunctions122Secondary Processing of Iron Ore1Location of Waste Rock Piles1Atmospheric EnvironmentDustAir Quality13Project PhasesMonitoring and Follow-UpPost Closure22Current Use of Lands and ResourcesCurrent Use of Lands and Resources forTraditional Purposes by Aboriginal PersonsVisual AestheticsPotential Interaction withExisting Aboriginal Rights/TitleFish Habitat113Freshwater Fish, Fish Habitat and FisheriesSpecies at Risk and Species ofConservation ConcernWetlandsFish PopulationCumulative Effects onFish and Fish HabitatSpecies at RiskWetlands111217

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryAboriginal Engagement ActivitiesAlderon recognizes the importance of building relationships based on mutual trustand respect with Aboriginal groups which may be affected by the Project in orderto achieve mutually beneficial outcomes. Alderon is committed to ensuring thatpotentially affected Aboriginal groups and communities are appropriately engagedso that Alderon can identify, understand and address any potential adverse effectsof the Project on those groups and communities and their current use of land andresources for traditional purposes.Alderon’s approach to engagement with Aboriginal groups is guided by itsAboriginal Relations Policy. Pursuant to the Aboriginal Relations Policy,Alderon will:• Acknowledge potential or established Aboriginal or treaty rightsand comply with the requirements of any applicable treaties,laws, regulatory measures and governmental policies;• Provide opportunities for Aboriginal groups to share traditional knowledgeand information on traditional land and resource use in the project area;• Develop an effective, respectful and meaningful engagement process; and• Work cooperatively and collaboratively with Aboriginal groups toidentify Project effects and develop and implement appropriatemitigation measures, including, where appropriate, the negotiation ofagreements to address adverse effects and provide access to benefits.Alderon has engaged with those Aboriginal groups and communities who havetreaty rights or recognized or asserted Aboriginal rights or Aboriginal title(collectively referred to as “Aboriginal Interests”) and who may be affected by theProject. In order to determine the existence of such Aboriginal Interests, Alderonhas reviewed a broad range of information in order to gain a general understandingof the nature of known Aboriginal Interests in the Project and to identify theAboriginal groups and communities which will be engaged by Alderon.Alderon has identified five Aboriginal groups with Aboriginal Interests whichmay be affected by the Project. These groups which form the participant list forAlderon’s Aboriginal engagement program are:• Innu Nation;• NunatuKavut Community Council;• Uashat mak Mani-Utenam;• Matimekush-Lac John; and• Naskapi Nation of Kawawachikamach.Alderon has made significant efforts to engage with each of these Aboriginalgroups. These efforts are based on Alderon’s Aboriginal Engagement Strategy andAction Plan which establishes the framework for a coordinated and comprehensiveengagement process which is consistent with the requirements of any applicabletreaties, laws, regulatory measures and governmental policies, including the EISGuidelines. The engagement process commenced prior to Project registration andwill continue throughout the life of the Project until closure and decommissioning.18

These engagement efforts consist of four main initiatives:• Information Sharing: Alderon has provided each Aboriginal group witha wide range of Project-related information for review and comment,including the Project registration, explanatory brochures, corporatepolicies and permit applications, translated as appropriate, and hasoffered to meet with each group to discuss this information and toprovide Project updates. This information has also been made availableon Alderon’s website. Alderon will continue to provide clear, userfriendlyand relevant Project-related information to each Aboriginalgroup on a timely and ongoing basis through the life of the Projectto enable the ongoing identification of issues and concerns.• Community Engagement: Alderon has met with the leadership of eachAboriginal group to discuss the Project, environmental assessmentand the engagement process in order to determine the best means oftransmitting Project-information and identifying issues and concerns.Alderon has also made repeated efforts to meet with community membersto discuss the Project. As part of community engagement, Alderon hasassessed the capacity of each Aboriginal group to participate meaningfullyin engagement and where appropriate, has offered to enter into formalengagement arrangements, supported by capacity funding and technicalexpertise. Alderon has made and will continue to make regular offers tomeet with both leadership and the community in order to provide multipleopportunities to each Aboriginal group and community to understandthe Project and identify its potential effects upon Aboriginal interests.• Traditional land and resource use studies: Alderon has offered toprovide funding and technical resources to each Aboriginal group toconduct traditional land and resource use studies and collect traditionalknowledge through participant interviews and the mapping of relevantland and resource uses. Where agreements have been concluded,the results of such studies have been used to augment Alderon’sunderstanding of Project effects upon traditional activities. Alderonhas also offered to engage directly with those members of Aboriginalcommunities who may be particularly affected by the Project.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary• Mitigation and Avoidance: Alderon will provide opportunities toAboriginal groups to be consulted on the development of mitigationor avoidance measures where, as a result of information generatedthrough engagement, it is determined that the Project is likely tohave adverse effects upon Aboriginal Interests or otherwise adverselyaffect traditional land and resource use. Such mitigation or avoidancemeasures may include environmental monitoring, land and culturalprotection measures and the negotiation of benefits agreements.Alderon will incorporate information gained during engagement intoProject planning and execution and will adapt plans as necessary totake into account the views of Aboriginal groups and communities.19

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryAlderon’s engagement efforts have enabled the various Aboriginal groups toidentify issues of particular concern. Only one Aboriginal group identified a specificissue in relation to the Kami Terminal. That group was Uashat mak Mani-Utenamwhich identified as an issue the need to be consulted in relation to the Project asa whole and not simply in relation to the Kami Terminal site. Alderon’s approachto engagement with Uashat mak Mani-Utenam and all other potentially affectedAboriginal groups has been a comprehensive one which includes both the KamiMine and the Kami Terminal.Post-Submission of EISFollowing submission of the EIS, Alderon will continue Aboriginal engagement,and public and stakeholder consultation activities. Alderon will continue effortsto engage with potentially affected and/or interested Aboriginal communities,including outreach to Band Councils, capacity building, and community meetingswhere identified as appropriate by community leaders.20

6.0 EXISTING ENVIRONMENTThe Kami Terminal lies within the Municipality of Sept-Îles on Port Authority ofSept-Îles Lands, adjacent to similar load-out operating facilities (Pointe-NoireTerminal). The Pointe-Noire Terminal has been in operation for many decadesand contains several industrial and port facilities similar to the Kami Terminal. Theregion has long been the center of natural resource exploitation and the mainresource industries are hydroelectricity generation and mining.Although the wide range of habitats in the Côte-Nord region makes the regionattractive to a variety of bird and wildlife species, the Kami Terminal site is inan industrialized area with few natural habitats. Remaining habitat at the KamiTerminal site consists mainly of patches of young mixed forest stands and matureconiferous stands.While freshwater fish habitat is present on the Peninsula, there is none in the KamiTerminal footprint.No species at risk, or species of conservation concern, were observed during fieldsurveys. According to the Centre de données sur le patrimoine naturel du Québec(CDPNQ) database, no flora species with special status are reported for the Portsite area (personal communication, MDDEP, July 2011).In 2009, Québec’s Côte-Nord Region was home to a population of approximately96,000, accounting for 1.2 percent of the Québec population. In 2009, Sept-Îleshad a population of 25,686 inhabitants. The closest residential and recreationalland uses is located approximately 1.5 km from the Kami Terminal site, in the lowdensity Val Sainte-Marguerite.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryThere are two Aboriginal reserves in the vicinity of the Kami Terminal site: Uashatand Maliotenam, which are located approximately 10 and 26 km, respectively,to the east of the Kami Terminal site. The Kami Terminal is located within thetraditional territory of two Aboriginal groups: the Innu of Uashat mak Mani-Utenam and the Innu of Matimekush-Lac John. Though located near Scheffervilleapproximately 500 km north of Sept-Îles, the Innu of Matimekush-Lac John sharetheir ancestral territory with the Innu of Uashat mak Mani-Utenam. Based on theinformation available, there is no evidence of current use of lands and resourcesspecifically for traditional purposes by Aboriginal Persons in the Kami Terminalarea. Additionally, no Historic and Cultural Resources have been identified in theKami Terminal area.21

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryThe EIS provides detailed descriptions of the existing biophysical and socioeconomicenvironments that could be affected by the Kami Terminal for each VEC.Details on each specific environmental component are found in the VEC analysis inChapters 14 through 26.In addition, baseline studies were completed on the following topics:• Freshwater fish, fish habitat and fisheries;• Water resources;• Air quality dispersion modelling; and• Socio-economic (including housing, labour force, communityservices, employment demands, local infrastructure).These stand-alone baseline studies support the evaluation of environmentaleffects, the development of mitigation measures and monitoring andfollow up programs.During the development of these baseline studies government and nongovernmentagencies have been engaged in the design and methodology for thecollection of data to help ensure a thorough and comprehensive basis for theenvironmental assessment.22

7.0 ENVIRONMENTAL EFFECTSASSESSMENT7.1 Method and ApproachActivities associated with each Kami Terminal phase and with accidental eventswere identified to evaluate potential environmental effects. The potentialenvironmental effects of each phase (construction, operations and maintenance,decommissioning and reclamation) have been assessed for each VEC, basedon the pre-existing conditions of each VEC and existing knowledge about theenvironmental effects of similar projects.Effects remaining after mitigation measures have been applied, also known asresidual effects are characterized using specific criteria (direction, magnitude,geographic extent, duration, frequency, and reversibility) that are defined for eachVEC. The significance of environmental effects was then determined based on predefinedcriteria or thresholds for determining the significance of the residual effect.Residual Effects Assessment Summary Matrices are provided in Appendix A.Alderon has undertaken a public consultation program and has engaged withpotentially affected Aboriginal groups to understand the issues and concerns ofstakeholders and Aboriginal groups. The environmental assessment focuses onthese issues and concerns, using an issues-based approach to help stakeholdersand Aboriginal groups identify how their issues have been addressed. The maincategories in which issues were raised are presented in the figure below on anoverall proportionate basis.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary23

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryProportion of Issues Identified During Aboriginal Engagement andPublic Consultation ActivitiesSpecies at Risk and Species ofConservation Concern2%Current use of lands and resourcesfor traditional purposes byAboriginal persons2%Current Use ofLands andResources6%Freshwater Fish, Fish Habitat andFisheries8%Birds, Other Wildlife and TheirHabitat, and Protected Areas13%Wetlands2%Community Services andInfrastructure21%Water Resources21%Atmospheric Environment8%Economy, Employment andBusiness17%24

Overview of Environmental Assessment MethodScoping of the AssessmentExistingConditionsSTEP 1STEP 2STEP 3STEP 4STEP 5STEP 6VEC SelectionRationale for Selection, Issues Identification, Regulatory SettingProject Interactions with the Environment• Identification of Environmental Effects• Screening of Project-Environment Interaction• Selection of Measurable ParametersIdentification of EA BoundariesEstablish Standards or Thresholds for Determining(also known as Significance Criteria)Describe Existing ConditionsAssessment of Project-Related Environmental Effects• Description of Project Environmental Effects• Mitigation of Project Environmental Effects• Characterization of Residual Project Environmental Effects• Assess and Respond to Issues Raised by Stakeholder GroupsOngoingConsultation andIssue ScopingKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryAssessmentSTEP 7Assessment of Cumulative Effects• Screening of Cumulative Effects• Identification of Other Projects and Activities• Characterization of Residual Cumulative EffectsRepeat forEach VEC andEnvironmentalEffectSTEP 8Determination of Significance• Residual Project-Related Environmental Effects• Residual Cumulative EffectsConclusionsSTEP 9STEP 10Follow-Up and MonitoringSummary25

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary7.2 Valued Ecosystem ComponentsThe environmental effects of the Kami Terminal have been assessed in accordancewith all applicable environmental assessment regulations, the EIS Guidelines andaccepted industry best practices. A summary of the results of the environmentalassessment for each VEC is presented below.7.2.1 Atmospheric EnvironmentThe Atmospheric Environment considers effects of the Kami Terminal on ambientair quality and the acoustic environment (noise). It also takes into considerationKami Terminal related greenhouse gases (GHGs), vibrations and change in lightemissions. Existing information for the study areas was first examined for theassessment and included local climate conditions, existing air pollution, noise andvibration sources, as well as results from recent provincial government air qualitymonitoring. In addition to using data from existing monitoring stations,the assessment drew largely from an air quality dispersion modeling studyconducted for the EIS. Currently, the industrial activities at the Port of Sept-Îlespresent a source of noise, light and air emissions however, noise and air emissionsremain below levels recommended by provincial and federal regulations andguidelines. There are no known sources of vibrations and light pollution levelsare considered low.26

!!!!!!!!!!!!!! !!!!Atmospheric Environment Local and Regional Study Areas±GallixClarkeVal Sainte-MargueriteAir Quality Study Area! !^_Baie Ste - MargueriteFerland! !! !Baie des Sept-ÎlesNoise Monitoring Local Study AreaTerminal SiteNoise Monitoring Regional Study AreaSept Îles! !! !! !PlagesGolfeCatallandu St - Laur ent! !MoisieFIGURE ID: ALD_ST_7060 3 6GHG emissions have the potential to cause environment effects on a large scale.Therefore the spatial boundary used for reviewing GHG emissions from the KamiTerminal is the province of QuébecIssuesIssues raised by the public and other stakeholders during engagement activitiesincluded dust and air quality. In response to these issues, Alderon is implementingvarious mitigation measures to control fugitive dust emissions during constructionand operations, including enclosed conveyors and dust collectors. Alderon willalso participate in the air quality monitoring effort that originated in Sept-Îles. Acomplete record of all comments with responses is included in Appendix B.KilometresKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryFrequency of issues raised during engagement activities4Number of Times Issue was Raised321310DustAir Quality27

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryPotential Environmental EffectsConstruction activities will result in emission of air contaminants such as dustand gas emissions from the combustion of fuel in construction equipment.These emissions will be temporary in nature and are expected to be withinregulatory objectives, standards, and guidelines. During the operations phase, railtransportation will release emissions from the diesel-powered engines and dustwill be released during the transfer and stockpiling of iron ore. Emissions and dustare expected to occur infrequently and be low in quantity, as well as remain closeto the Kami Terminal site.Vibrations and sound emissions will result from construction activities and thetransfer of concentrate from rail to container ships. The communities of ValSainte-Marguerite and Sept-Îles are separated from the facility by 5 and 10 kmrespectively, and are unlikely to experience noise resulting from activities atKami Terminal. Due to the distance from the Kami Terminal site to the nearestcommunities, vibrations from the operation of heavy construction equipment willgenerally not be of concern. Artificial lighting will be used at the Kami Terminalsite during construction and operations and could potentially result in effects onambient light and the night sky. However, construction activities will be short induration and during operations, permanent lighting will be installed using the locallandscape as a shield.Mitigation MeasuresRail car dumping will occur in a closed building, conveyors will be enclosed, dustsuppressants and a dust collector system will be used to minimize the releaseof dust particles. Also operations will adhere to a comprehensive equipmentmaintenance program, monitoring programs and proper light installation will helpto minimize effects.Residual Environmental EffectsGiven the implementation of mitigation measures, the Kami Terminal is notlikely to result in significant adverse environmental effects under normaloperating conditions.28

7.2.2 Landforms, Soils, Snow and IceLandforms, Soils, Snow and Ice includes consideration of landforms, terrainstability, soil quality and quantity, snow and ice as well as the potential for acidrock drainage and metal leaching. The effects of the Kami Terminal on Landforms,Soils, Snow and Ice are mainly discussed under Atmospheric Environment andWater Resources in the EIS. For acid rock drainage and metal leaching, existinginformation was analyzed, including results from bedrock geology testing,photointerpretation and terrain mapping.IssuesNo issues were raised during Aboriginal engagement and public consultationactivities regarding Landforms, Soils, Snow and Ice at the Kami Terminal.Potential Environmental EffectsThere are no sensitive or valuable landforms within the Kami Terminal site. Mostof the soils within the Kami Terminal area are already disturbed by previous orongoing industrial activities. No natural undisturbed soils are present in the Portarea other than a hillside where part of the concentrate unloading, stacking,storage and reclaiming facility will be located. The hillside will need to be leveledusing specialized blasting techniques. The rock material from the blasting will becrushed and used for construction purposes at the site. Early ice breakup is also notconsidered to be an issue since there are no lakes that freeze-up within or closeto the Kami Terminal area that could be affected by airborne dust particles fromactivities at the Port. In consideration of the absence of valuable landforms andthe irrelevance of snow and ice to the Kami Terminal, no assessment of Landforms,Soils, Snow and Ice was conducted in the EIS. Acid rock drainage and metalleaching are assessed in the Water Resources VEC.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryMitigation MeasuresAs described further in the Water Resources assessment, mitigation measuresfor soils include erosion control measures which will be implementedduring construction.29

!!!!!!!!!!!!!! !!!!Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryResidual Environmental EffectsThe residual environmental effects of the Kami Terminal on Landforms, Soils,Snow and Ice are discussed in Chapters 14 (Atmospheric Environment) and 16(Water Resources) of the EIS. The assessments conducted for red water, acid rockdrainage, metal leaching and dust emissions show that the Kami Terminal is notlikely to result in significant adverse residual effects on Landforms, Soils, Snow andIce under normal operating conditions.7.2.3 Water ResourcesWater Resources include the quality and quantity of groundwater and surfacewater resources for the area surrounding the Kami Terminal. In June 2012, Alderoncollected surface water samples from Kami Terminal area streams as well asfrom the baie des Sept-Îles. The samples were analyzed for water quality and theresults were compared to the provincial and federal standards. Concentrations ofwater pollutants were significantly below the water quality criteria in the MDDEPDirective 019 for the mining industry, with the exception of pH and total suspendedsolids. Concentration of metals such as aluminum, copper and iron exceedingthe Canadian Council of Ministers of the Environment Canadian Water QualityGuidelines for the Protection of Aquatic Life and/or the Québec Surface WaterCriteria were detected. Considering that the ore concentrate storage area andthe stormwater retention pond will be lined and that runoff in the Kami Terminalarea will be contained and treated before being released into the environment,gathering groundwater was deemed unnecessary for assessment purposes.Water Resources Local and Regional Study Areas±Regional Study AreaFerland! !ClarkeBaie des Sept-ÎlesSept Îles! !! !! !PlagesCatallan! !MoisieMunicipality of Sept-Îles BoundaryVal Sainte-MargueriteLocal Study Area! !^_! !GallixBaie Ste - MargueriteTerminal SiteGolfedu St - Laur entFIGURE ID: ALD_ST_7070 3 6Kilometres30

IssuesIssues identified by participants related to Water Resources included effects onwaterbodies, water quality, water management at the Kami Terminal site, andcumulative effects. In response to these issues, Alderon will implement mitigationmeasures such as a water management plan, water treatment including treatmentof red water, and dust control. A complete record of all comments with responsesis included in Appendix B.Frequency of issues raised during engagement activitiesNumber of Times Issue was Raised432103 3Waterbodies Water Quality WaterManagement2 2Cumulative Effectson WaterResourcesPotential Environmental EffectsConstruction phase activities will require a stream diversion and installation ofwatercourse crossings. The rerouting will change the local drainage pattern over ashort distance. Testing of geologic materials was conducted to assess the potentialfor acid rock generation and metal leaching resulting from site preparationactivities such as blasting and site preparation. Results of geologic testing suggestthat acid rock drainage will not likely arise from the Kami Terminal activities, or useof materials from the site.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryMitigation MeasuresLocal water quality and quantity will be protected by complying with all regulationsand guidelines and implementation of best management practices for spillprevention, surface water management, materials handling, erosion, and sedimentcontrol planning. Slopes will be stabilized and engineered to reduce erosion. Aspart of design, the concentrate storage yard will also be lined and water runoff willbe collected and treated before release in order to protect local water qualityResidual Environmental EffectsGiven the implementation of mitigation measures, the Kami Terminal is notlikely to result in significant adverse environmental effects under normaloperating conditions.31

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary7.2.4 WetlandsWetlands were included in the EIS Guidelines because wetland environments areimportant habitat for many wildlife and plant species, water quality and quantityas well as in recognition of the federal and provincial policies concerning wetlands.Wetlands were also raised as an issue during the consultation process. However, nowetlands were identified within the Kami Terminal site, and for that reason it wasdetermined that no assessment of the VEC was necessary.IssuesAn issue was raised regarding the presence of a protected wetland in thePointe‐Noire area. This potential wetland does not overlap with the Kami Terminaland is unlikely to be affected.7.2.5 Freshwater Fish, Fish Habitat and FisheriesThe EIS Guidelines state that Freshwater Fish, Fish Habitat and Fisheries mustbe considered as a VEC. Freshwater fish and fish habitat means freshwater fishspecies and the habitat upon which they depend. Two freshwater streams arelocated in the local study area however neither of these streams provide habitatthat supports freshwater fish populations. As there are no fish present at the KamiTerminal, there is no potential for fisheries. Due to the lack of fish, fish habitat andfisheries, it was determined that assessment of the VEC was not necessary.IssuesIssues were raised by participants regarding cumulative effects on fish in themarine environment. Issues associated with freshwater fish concerned the ruisseauà la Baleine and rivière Nipississ, which is located more than 40 km north of theKami Terminal site.Frequency of issues raised during engagement activities3Number of Times Issue was Raised2102Cumulative Effects on Fish andFish Habitat1 1Fish HabitatFish Population32

!!!!!!!!!!!!!!!7.2.6 Birds, Other Wildlife and TheirHabitats and Protected AreasBirds, Other Wildlife and Their Habitats, and Protected Areas include migratoryand non-migratory birds, amphibians, small mammals, ungulates, and furbearers.Protected Areas are also considered as a component because of the potential forinteractions between Kami Terminal activities and existing or planned designatedprotected areas, and the need to protect ecosystems, species diversity, importanthabitats, and ecosystems.Information on existing conditions was collected and analyzed through a literaturereview, review of government databases, and habitat mapping. This informationwas used to determine the likelihood of a presence of bird and other wildlifespecies and wildlife habitat within the study area. Field studies for birds, reptiles,and amphibians were also conducted by qualified biologists in the Kami Terminalarea in 2011.The Port of Sept-Îles is a highly disturbed industrial area and provides poor qualityhabitat for wildlife. Such conditions are not favourable to large mammals such asbears, moose, or caribou, as they prefer large, undisturbed habitats. All of the 33species of birds and 4 species of amphibians observed during the field studies arecommon in Québec.Birds, Other Wildlife and their Habitats and Protected Areas Local and Regional Study Areas±Municipality of Sept-Îles BoundaryRegional Study Area! ! !! !Sept-Îles! ! !Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary! ! !! !! !Baie des Sept-Îles! !Port of Sept-Îles Property! !^_! ! !Local Study AreaTerminal SiteWaterfowlGathering AreaBaie Ste - MargueriteGolfe du St - LaurentFIGURE ID: ALD_ST_7140 2 4KilometresIssuesIssues identified by participants related to Birds, Other Wildlife and Their Habitats,and Protected Areas included effects on wildlife species, waterfowl, and parks andprotected areas. An issue was raised regarding the presence of a protected wetlandin the Pointe-Noire area. This potential wetland does not overlap with the KamiTerminal site and is unlikely to be affected. In response to the issues associatedwith wildlife and waterfowl, Alderon conducted field surveys to identify habitatand species potentially affected by the Kami Terminal. Alderon will also implement33

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summarymitigation measures to minimize dust emissions, and will implement standard bestpractice as well as avifauna and wildlife protection measures. A complete record ofall comments with responses is included in Appendix B.Frequency of issues raised during engagement activitiesNumber of Times Issue was Raised4321032Wildlife Species Waterfowl Parks and Protected AreasPotential Environmental EffectsAll Kami Terminal activities during the operation and maintenance, anddecommissioning and reclamation phases (site clean-up and transfer of equipmentto another company) will occur within areas that are mostly already disturbedand are unlikely to result in a change in habitat. Additional disturbance to habitatscreated by the Kami Terminal is unlikely to result in significant environmentaleffects on wildlife and their habitat.Construction activities will, through sensory disturbance (such as noise), have aneffect on distribution and movement of birds and other wildlife. However, theseactivities will occur in an industrial area that is already a source of noise. Nearbywildlife are already exposed to noise levels at the Port. Changes in mortality riskwill mostly be linked to direct mortality from collision with constructionvehicles. However, this activity would mostly occur in disturbed areas of an activeport site, by relatively slow-moving vehicles. Airborne contaminants emittedduring construction and operations may potentially cause changes in health ofbirds and wildlife.1Mitigation MeasuresEffects on birds, other wildlife and their habitat, and protected areas will bemitigated through a series of measures designed to limit the area disturbed by theProject and then to control the emissions and discharges. The primary mitigationmeasures for Project-related effects include an Avifauna Management Plan,restricting clearing to the period outside the breeding bird season (where feasible),and no harassment of wildlife on the Project site.Residual Environmental EffectsGiven the implementation of mitigation measures, the Project is not likely to resultin significant adverse environmental effects under normal operating conditions.34

!!!!!!!!!!!!!!!7.2.7 Species at Risk and Species of Conservation ConcernSpecies at risk and species of conservation concern include any particularspecies of plant or animal, or its critical habitat, that is of provincial, national orinternational importance, particularly where the species or its critical habitatis afforded protection under federal or provincial legislation. Historical records,literature reviews, and databases provided information to determine if speciesat risk or species of conservation concern are likely to exist in or near the KamiTerminal site. In addition, aerial photographs and digital mapping was used tointerpret habitat type and distribution. General habitat conditions were confirmedduring the 2011 field studies.Various field surveys and habitat assessments completed during the 2011 and2012 field seasons found no species at risk or species of conservation concern inthe Kami Terminal area. While a few mammal and bird species, such as woodlandcaribou and Canada Warbler, have been reported in the region, habitat conditionsin the Kami Terminal area are not suitable for these species.Species at Risk and Species of Conservation Concern Local and Regional Study Areas±Municipality of Sept-Îles BoundaryRegional Study AreaBaie des Sept-Îles! ! !! !Sept-Îles! !! !! !! ! !! ! !Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryPort of Sept-Îles Property! !^_! ! !Local Study AreaTerminal SiteWaterfowlGathering AreaBaie Ste - MargueriteGolfe du St - LaurentFIGURE ID: ALD_ST_7140 2 4KilometresIssuesOne issue was raised regarding the presence of bird species at risk and migratorybirds. Although the Kami Terminal site does overlap with the geographic range ofsome bird species at risk, the field surveys did not identify any rare bird species inthe vicinity of the Kami Terminal.Potential Environmental EffectsApproximately 45 percent of the land at the Kami Terminal site was previouslydeveloped (22.6 ha). Site preparation for construction of the Kami Terminal willalter less than 1 percent of the land on the Marconi Peninsula, excluding previouslydeveloped areas. Therefore, it is unlikely that there would be any change in theamount of (potential) critical or important habitat of species at risk or species ofconservation concern.35

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryMitigation MeasuresEffects on species at risk and species of conservation concern will be mitigatedthrough the development of protection measures and environmental managementtechniques based on site-specific conditions. This will include avoiding sensitivespecies or habitats, if found, and complying with existing legislation.Residual Environmental EffectsGiven the implementation of mitigation measures, the Project is not likely to resultin significant adverse environmental effects under normal operating conditions.7.2.8 Historic and Cultural ResourcesHistoric and Cultural Resources include sites, materials, landscapes, or places ofhistoric, archaeological, cultural / spiritual, palaeontological, and architecturalimportance. Archaeological sites and materials have been identified throughoutthe majority of Québec including the Côte-Nord region and Sept-Îles. The provincialinventory of archaeological resources for Québec reports the existence of 14sites of archaeological significances within the Regional Study Area. No sites wereidentified in the Kami Terminal area.36

!!!!!!!!!!!!!! !!!!±Historic and Cultural Resources Local and Regional Study AreasGallixRegional Study AreaClarkeVal Sainte-Marguerite! !Baie Ste - Marguerite^_FerlandBaie des Sept-ÎlesLocal Study Area! !! !! !Sept Îles! !Terminal Site! !PlagesGolfedu St - Laur ent! !CatallanFIGURE ID: ALD_ST_7090 3 6KilometresMoisieMunicipality of Sept-Îles BoundaryIssuesNo issues related to Historical and Cultural Resources were reported duringAboriginal engagement and public consultation.Potential Environmental EffectsAlthough no archaeological sites have been found to date within the Local StudyArea, Kami Terminal activities could potentially unearth archaeological sites duringconstruction activities. However, because there are no known archaeological siteswithin the Local Study Area, the Kami Terminal is not likely to affect, or physicallydisturb sites of archaeological importance.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryMitigation MeasuresIn the event of the unexpected discovery of historical and cultural resources duringconstruction, mitigation measures will be implemented in accordance with theCultural Property Act (2006) and with the Cultural Heritage Act which will come ineffect in October 2012.Residual Environmental EffectsThe Kami Terminal is not likely to result in significant adverse environmental effectsunder normal operating conditions.37

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary7.2.9 Current Use of Lands and Resources forTraditional Purposes by Aboriginal PersonsThe Current Use of Land and Resources for Traditional Purposes by AboriginalPersons is defined as per the EIS Guidelines as the “use of lands and resources ofspecific social, cultural or spiritual value to Aboriginal communities of Labradorand Québec, with focus on current direct and indirect use by Aboriginal people fortraditional purposes (i.e., fishing, hunting, and gathering)”.A number of Aboriginal groups undertake traditional land and resource useactivities in areas of Québec and Labrador. The land claims of these groups areat varying stages of negotiation and settlement. The Current Use of Land andResources for Traditional Purposes by Aboriginal Persons and the potential effectsof the Kami Terminal on these activities are a key element of the EA, given theoverall socio-economic importance of these activities to Aboriginal peoples. This isfurther reflected in the CEAA definition of “environmental effect”, which specificallyincludes: “(a) any change that the project may cause in the environment, ….[and](b) any effect of any change referred to in paragraph (a) on … (iii) the current use oflands and resources for traditional purposes by Aboriginal persons...”.As reflected in the title of this VEC, the associated environmental effectsassessment focuses upon the current (existing) use of land and resources byAboriginal persons for traditional purposes, and potential changes to theseactivities that may occur— either directly or indirectly — as a result of the KamiTerminal.38

Current Use of Land and Resources for Traditional Purposes by Aboriginal Persons Local andRegional Study Areas±Kawawachikamach(Naskapi Nation)TshiuetinRailwayLabrador CityFermontKami Mine Site! !^_!( !( !!(!(Matimekush - Lac John(Québec Innu)WabushNatuashish !((Labrador Innu)Local Study Area^_A T L A N T I CO C E A N!( Sheshatshiu(Labrador Innu)Terminal SiteKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryTerminal Site^_Quebec North Shoreand Labrador RailwaySept ÎlesUashat Mak Mani-Utenam(Québec Innu)Golfe du St - LaurentRegional Study AreaFIGURE ID : ALD_ST_7130 50 100KilometresIssuesAlderon has been making significant efforts to engage with each of the relevantAboriginal communities and organizations in Québec and Labrador in order togather information on current land and resource use, Aboriginal knowledge andcommunity issues, and concerns regarding the Project including its potentialenvironmental effects, for consideration and incorporation into the EIS. WhereAboriginal groups have chosen to participate in such initiatives, the informationand insights obtained through these processes have been extremely valuableand have been considered and incorporated throughout the environmentalassessment. In other cases, the EIS uses existing and publicly available information.During Aboriginal engagement activities, the Innu of Uashat mak Mani-Utenamidentified that they should be engaged on the Project as a whole, and not only thecomponents at the Port of Sept-Îles.39

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryPotential Environmental EffectsThe construction and operation phases of the Kami Terminal will alter some ofthe existing landscape. However, the area upon which Alderon’s proposed KamiTerminal at the Port of Sept-Îles will be constructed and operated has been thesite of on-going industrial activity for several decades. The Kami Terminal is locatedin an industrial area designated for large-scale industry. This industrial area hasbeen the site of substantial and long-standing industrial activity. Likely as a resultof these factors, available information does not indicate that traditional landand resource use activities occur within the Kami Terminal site. There are alsono known sites of historical, cultural, or spiritual importance to the Aboriginalcommunities within the Kami Terminal site. Assessments of the potentialimplications of the Kami Terminal for vegetation, fish, wildlife, and other resourceshave been assessed in detail for the other VECs. These assessments conclude thatthe Kami Terminal is not likely to cause significant adverse environmental effectson any aspect of the natural environment. Additionally, since key resources such ascaribou are not found in the area or likely to be affected, the Kami Terminal is notlikely to have any effect upon the distribution (location or timing) of the current useof land and resources for traditional purposes by Aboriginal persons.Mitigation MeasuresThe consideration of environmental issues from the earliest stages of projectplanning and design has been a key part of Alderon’s approach to its proposedfacility. This approach allows potential environmental issues and interactions to beidentified early, so that they can be addressed. The objective is to attempt to avoidadverse environmental effects where possible and practical, or at least, to put inplace mitigation measures to ensure that they are maintained at acceptable levels.For example, siting of Kami Terminal components and activities entirely within anexisting industrial zone will limit the effects of the Kami Terminal on Current Use ofLand and Resources for Traditional Purposes by Aboriginal Persons.Residual Environmental EffectsThe Kami Terminal is not likely to result in significant adverse environmental effectsunder normal operating conditions.7.2.10 Other Current Use of Lands and ResourcesOther Current Use of Lands and Resources is focused on current (1990 to present)land use and activities, including industrial uses, undertaken by non-Aboriginalpersons or communities in or around the Kami Terminal site. In order to assess howthe Kami Terminal could affect industrial development and activities in the Pointe-Noire industrial area as well as surrounding residential and recreational properties,Alderon gathered information on current industrial users, future industrialexpansion plans and the location of residential and recreational lands.Six iron ore companies use the Port of Sept-Îles’ facilities and have plans forincreased production. Alderon’s ore storage terminal is included in the Port’sdevelopment plans and the site location for the storage yards was determined bythe Port Authority. The closest residential and recreational land is the Val Sainte-Marguerite area located about 1.5 km away from the Kami Terminal site.40

!!!!!!!!!!!!!! !!!!Other Current Use of Lands and Resources Local and Regional Study Areas±Regional Study AreaGallixClarkeVal Sainte-Marguerite! !^_Baie Ste - MargueriteFerlandBaie des Sept-ÎlesLocal Study Area! !! !! !Sept Îles! !Terminal Site! !PlagesGolfedu St - Laur ent! !CatallanMoisieMunicipality of Sept-Îles BoundaryFIGURE ID: ALD_ST_7080 3 6IssuesIssues identified by participants related to visual aesthetics of the port facilitiesincluding the concentrate stockpiles. It is important to note that the residentialarea of Sept-Îles is located several kilometers from the kami Terminal and will bevirtually indistinguishable from other existing industrial port facilities. A completerecord of all comments with responses is included in Appendix B.KilometresKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryPotential Environmental EffectsThe environmental assessment of other current use of lands and resources isfocused on changes to industrial development and changes to residential andrecreational property. Assessment of effects on industrial development consideredactivities that would lead to the exclusion or promotion of industrial activity at theport. Effects to residential and recreational property were considered in terms ofthe effects of potential changes in air quality, noise, vibrations and light quality.Potential VEC interactions for these two effects are associated with the two-yearKami Terminal construction phase, and the operations and maintenance phase.Changes to viewscapes were considered to be not significant due to the distancebetween vantage points from the existing infrastructure at Pointe-Noire.Construction of the Kami Terminal will require realignment of an access road andunderground water main in the Pointe-Noire industrial area. Site preparation andconstruction may also result in changes to the atmospheric environment, mainly airand noise emissions, light quality and vibrations. This has the potential to disturbresidential and recreational users in the near Val Sainte-Marguerite area.Mitigation MeasuresMitigation measures to minimize adverse effects include the realignment of anaccess road, water main and stockpile rocks to minimize effects on the AluminerieAlouette aluminum smelter; use of dust suppressants, enclosed conveyor systems,and transfer points; and adherence to comprehensive equipment maintenanceand monitoring programs.41

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryResidual Environmental EffectsGiven the implementation of mitigation measures, the Kami Terminal is notlikely to result in significant adverse environmental effects under normaloperating conditions.7.2.11 Community Services and InfrastructureCommunity Services and Infrastructure was selected as a VEC because theKami Terminal has the potential to reduce access to housing and increase trafficcongestion in the City of Sept-Îles. Information on the current housing supply andhousing costs, potential increases in the number of workers, existing employmentconditions, trends in the construction sector, and local traffic conditions and trendswas collected for the assessment of effects.Currently there is a shortage of both skilled and unskilled construction labourin Sept-Îles. In addition, housing has been identified as a major issue in the citybecause there is a lack of new housing construction. Traffic congestion has beenidentified as a problem on Highway 138 during shift changes at the nearby smelterand pellet plant.Community Services and Infrastructure Regional Study Area±^_Regional Study AreaQuebec North Shoreand Labrador RailwayExisting RoadsLocal Study Area^_!Sept ÎlesTerminal SiteGolfe du St - LaurentFIGURE ID : ALD_ST_7120 10 20Kilometres42

IssuesIssues identified by participants related to availability of housing for workers,potential effects on community services, and cumulative effects. In response tolocal concerns, Alderon has engaged with local authorities to address issues relatedto infrastructure, as needed. A complete record of all comments with responses isincluded in Appendix B.Frequency of issues raised during engagement activitiesNumber of Times Issue was Raised5432104Availability of Housing for Workers3 3Potential Effects on CommunityServicesCumulative Effect on CommunityServices and InfrastructurePotential Environmental EffectsPotential effects of the Kami Terminal on community services and infrastructureare only expected in association with the construction phase since the operationsand decommissioning phases will not have large staffing requirements. An influxof between 30 and 300 workers, depending on construction activities, is expectedduring the approximately two-year construction phase of the Kami Terminal,including 50 workers required for the construction of the Kami Terminal railcomponents by CFA. A large part of the workforce required for construction willhave to be recruited from outside the region due to the limited availability ofqualified workers in the Sept-Îles area. The arrival of a number of workers fromoutside the region is expected to contribute to the ongoing scarcity of availablehousing and to put additional upward pressure on housing costs in the region.The transportation of personnel associated with this influx of workers could alsoworsen traffic congestion on Highway 138 between the downtown area of Sept-Îlesand Kami Terminal.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryWorkforce requirements during operations will be approximately 17 workers. It isanticipated that this will not result in substantial additional demand on communityservices and infrastructure.Mitigation MeasuresTo minimize the effects of construction activities in the Kami Terminal area onregional housing supply, Alderon will engage with local authorities and otherstakeholders to address issues related to community services and infrastructureas needed.Residual Environmental EffectsGiven the implementation of mitigation measures, the Kami Terminal is notlikely to result in significant adverse environmental effects under normaloperating conditions.43

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary7.2.12 Health and Community HealthAlthough Health and Community Health was identified in the EIS Guidelinesfor assessment, given the characteristics of the Kami Terminal and its distancefrom the main population center in Sept-Îles, the atmospheric environment isconsidered as being the only pathway for potential effects on human health.Potential health effects could occur through dust generation, increased noise levelsand vibrations. Health issues associated with the atmospheric environment areassessed in the Atmospheric Environment VEC (Section 7.2.1 of this summary).IssuesNo issues related to Health and Community Health were reported.7.2.13 Economy, Employment and BusinessEconomy, Employment and Business was selected as a VEC due to the potentialfor improved economic conditions, increased levels of employment, and increasedbusiness activity in the city of Sept-Îles and Municipalité régionale de comté (MRC)de Sept-Rivières, in the Côte-Nord administrative region and in the province ofQuébec as a whole.In order to understand current economic conditions, information was gathered onemployment, income, and businesses for the Côte-Nord Administrative Region,MRC de Sept-Rivières, City of Sept-Îles, and Innu communities near Sept-Îles.The principle resource-based industries in the Côte-Nord Administrative Region arebased on the extraction and processing of mineral and forest resources. The miningsector also plays an important role in employment and income in Sept-Îles.The main employer for Innu communities of Sept-Îles is the Band Councilalthough construction training programs enable younger generations toacquire marketable skills.44

Economy, Employment and Business Local and Regional Study Areas±U n g a v a B a yTshiuetinRailwayLocal Study Area!!!^_Labrador CityWabushFermontKami Mine Site!^_ScheffervilleQuebec North Shoreand Labrador RailwaySept ÎlesTerminal SiteA T L A N T I CO C E A NKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryRegional Study AreaU.S.AFIGURE ID : ALD_ST_7100 80 160KilometresIssuesIssues identified by participants related to effects on local businesses, cumulativeeffects, apprenticeship and training, availability of local workers, and potentialeffects on the local economy. Alderon will collaborate with the regional economicforum, coordinate disruptions to utilities and infrastructure to minimize effectsas well as promote regional subcontracting clauses for materials and services. Acomplete record of all comments with responses is included in Appendix B.45

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryFrequency of issues raised during engagement activitiesNumber of Times Issue was Raised432103Potential Effects on LocalBusinesses21 1 1Cumulative Effects on Apprenticeship and Training Availability of Local WorkersEconomy, Employment andBusinessPotential Effects on LocalEconomyPotential Environmental EffectsThe potential environmental effects of the Kami Terminal on the economy,employment and business relate to the construction and operations andmaintenance phases. It is expected that the construction phase will result in apositive effect on regional employment. Though a large part of the workforcerequired for construction will have to be recruited from outside the region dueto the limited availability of qualified workers in the Sept-Îles area, it will increaseopportunities for unemployed workers or young apprentices from the surroundingregions of eastern Québec and elsewhere that are affected by high levels ofunemployment. The construction phase may also produce positive effects forregional business.Mitigation MeasuresAlderon will collaborate with a newly-created regional economic forum to find themost appropriate approaches to optimizing regional employment and businessopportunities during the construction phase of the Kami Terminal.Residual Environmental EffectsGiven the implementation of mitigation measures, the Kami Terminal is notlikely to result in significant adverse environmental effects under normaloperating conditions.46

7.3 Effects of the Environment on the Project7.3.1 Method and ApproachFor the purpose of assessing the effects the environment may have on the Project,researchers selected a local study area which includes the Marconi Peninsula,the surrounding coastal area, and the baie des Sept-Îles. To evaluate howenvironmental factors such as climate and seismic events may affect the Project,a larger geographic area was selected because these environmental factors aregenerally more widely felt.7.3.2 IssuesNo comments or issues related to effects of the environment on the Project wereraised during Alderon’s engagement activities. A complete record of all commentswith responses is included in Appendix B.7.3.3 Potential Environmental EffectsThe assessment of effects of the environment on the Kami Terminal considershow local conditions and natural hazards, such as severe and/or extreme weatherconditions and external events — such as flooding, ice jams, rock slides, landslides,fire, outflow conditions and seismic events — could adversely affect the KamiTerminal and how this in turn could affect the environment, for example throughenvironmental emergencies due to extreme environmental conditions.EnvironmentalConditionSevere WeatherLong TermClimate ChangeSeismicityPotential Effects• Tidal storm surge and sea water level changes could resultfrom severe weather. Equipment and structures of the KamiTerminal are installed at elevations above sea level that willprevent possible damage due to severe storms.• Wind driven on-shore ice flows could occur however equipment locationand harbor barrier islands will minimize the potential for damage.• Over the next 100 years, Atlantic Canada will likely experience warmertemperatures, a greater frequency of storm events, increasing stormintensity, rising sea level, storm surges, coastal erosion and flooding.• Potential effects of climate change on operation of the KamiTerminal would be primarily related to increases in the frequencyof adverse weather events and changes in precipitation.• Increases in extreme weather events could potentially affect operation ofthe Project by increasing unscheduled maintenance due to storm damage.• A tsunami related event could potentially damage pier and shore areafacilities, depending on the wave height, but is low probability dueto water depth and the protection offered by the barrier islands.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary7.3.4 Mitigation MeasuresThe primary mitigation is sound planning. All engineering design will adhereto national and international standards. Building codes consider physicalenvironmental criteria such as temperature, wind, snow, and ice loading, anddrainage. In addition, the design life is taken into consideration so that materialsare chosen with sufficient durability and corrosion resistance.47

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary7.3.5 Residual Environmental EffectsPlanning and design of the Kami Terminal has and will continue to considerextreme climatic, hydrologic, and geo-hazard criteria. Experience of other ironore transportation companies in the area combined with prescribed codes andstandards provide a high level of confidence that environmental conditions are notlikely to significantly affect the Kami Terminal. Site monitoring will be undertaken toidentify potential problems and verify effective mitigations. As such, no significantadverse effects of the environment on the Kami Terminal are anticipated.7.4 Effects of Possible Accidents or Malfunctions7.4.1 Method and ApproachThe potential environmental effects of each potential Accident and Malfunctionwas assessed for each VEC, based on the existing conditions of each VEC andexisting knowledge about the environmental effects of the accidental events. Fiveaccidental event scenarios were developed for the Kami Terminal EIS including trainderailment, forest fire, stormwater retention pond overflow or breach, product spillat port, and premature shutdown.7.4.2 IssuesDuring Aboriginal engagement and public consultation, Alderon listened toquestions and concerns expressed by stakeholders and the public. One concernregarded the overflow of the retention pond and its impacts on operations (nouse of water). A complete record of all comments with responses is includedin Appendix B.7.4.3 Potential Environmental EffectsPotential accidents and malfunctions that may occur as a result of Kami Terminalactivities are identified and assessed for the five reasonable worst case scenarios.Train DerailmentAlderon will rely on rail service providers (QNS&L Railway and CFA Railway) toensure that the risks of train derailments are minimized. QNS&L and CFA have goodsafety records and their performance suggests that the likelihood of a rail spill offuel or derailment is low. Regular vehicle maintenance and efficient route planningwill be encouraged.Forest FireThe terminal facility is located next to a forested area. Although unlikely, KamiTerminal activities involving the use of heat or flame could result in a fire. Theextent and duration of a resulting fire would be dependent on response effortsand weather conditions. Staff will be trained to prevent and control fires. A planfor preventing and combating forest fires will be incorporated into the EmergencyResponse Plan.Storm Water Retention Pond Breach or OverflowA storm water retention pond will be created in order to collect site runoff,potentially including red water, generated from precipitation water runoff from theiron ore stockpiles. Red water from the pond will be treated before it is released48

into the ruisseau à la Baleine. However, in the unlikely event of a breach oroverflow at the storm water retention pond, red water could be released tothe downstream environment. In such an event, the receiving waters shouldrapidly recover.Mitigation measures in order to prevent/address a breach or an overflow of thestormwater retention pond include:• Continuous monitoring of the water level in the pond,and generally maintained at minimum levels; and,• Regular inspection of containment structures.The stormwater retention pond will be lined in order to prevent red water fromleaking into the underlying soils and into to the groundwater. The liner will bedesigned, installed, and quality-controlled using standard and best practices inorder to minimize the risks of leakage and will conform to Port requirements.Mitigation measures include regular sampling of treated water.Product Spill at PortIron ore concentrate will be carried from the stockpiles at the terminal facility tothe proposed Port Authority common offload point at the Port of Sept-Îles usingenclosed conveyors. Product loading of ships will be managed by the Port, whichwill comply with all applicable laws and regulations. Conveyors are designed andbuilt in order to prevent spillage of product.Premature or Permanent ShutdownIt is currently planned that the mine will be operational until approximately theend of 2033, at which time the facility would be transferred to the Port of Sept-Îlesfor use by other clients. Premature shutdown could also occur following changes inmarket conditions or other factors that result in the premature shutdown ofthe mine.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryIn the unlikely event of any of these scenarios, adverse environmental effectscould result. An Emergency Response Plan will be developed prior to initiation ofconstruction activities and will include detailed measures for responding to theaccidents and malfunctions listed above.7.4.4 Residual EffectsAccidents and malfunctions could generate significant effects. However, bydefinition they have a very low likelihood of occurring. Prevention and emergencyresponse measures will be implemented.49

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary7.5 Effects on Capacity of Renewable ResourcesA required component of a comprehensive study is to “address the capacity ofrenewable resources that are likely to be significantly affected by the project tomeet the needs of the resent and the future”. Renewable resources that may beaffected by the Kami Terminal are:• Water resources; and,• Waterfowl and other wildlife.Considering the design and the implementation of mitigation measures, nosignificant negative effects are likely to occur, and as a result, negative KamiTerminal effects on the capacity of renewable resources to meet the needs of thepresent and those of the future are not anticipated.7.6 Cumulative Environmental Effects7.6.1 ApproachThe overall effect on each VEC as a result of the Kami Terminal’s residualenvironmental effects in combination with the environmental effects of otherrelevant projects and activities that have been or will be carried out was assessed.Cumulative effects were assessed in the Regional Study Area specific to each VEC(i.e., the spatial boundaries in which cumulative effects are predicted to occur),and the assessment focuses on the degree of change from baseline VEC conditionsresulting from the Kami Terminal acting in combination with other relevant ongoingand future projects.7.6.2 ScopingOn-going and reasonably foreseeable future projects with environmental effectsthat are likely to overlap in space and time with those of the Kami Terminal include:• Pointe-Noire Port Expansion;• CFA and QNS&L;• Aluminerie Alouette Aluminum Smelter Project;• Second Port-Cartier Pellet Plant;• Bloom Pointe-Noire Terminal; and,• Arnaud Apatite-Magnetite Mine.7.6.3 IssuesIssues identified during Aboriginal engagement and public consultation activitiesthat relate to cumulative effects are presented in Appendix B. The mitigation andeffects management measures proposed by Alderon will mitigate theoverall cumulative effect of the Kami Terminal in combination with otherprojects and activities.50

7.6.4 Potential Cumulative EffectsOngoing and reasonably foreseeable future projects that are likely to overlap inspace and time with those of the terminal facility are identified in the table belowas a “Y” to represent a cumulative effect on the VEC.Name of Project/ActivityPointe-Noire PortExpansionAtmospheric EnvironmentLandforms, Soils, Snow and IceWater ResourcesWetlandsFreshwater Fish, Fish Habitatand Mortality and FisheriesBirds, Other Wildlife and TheirHabitats, and Protected AreasSpecies at Risk and Species ofConservation ConcernHistoric and Cultural ResourcesCurrent Use of Lands and Resources forTraditional Purposes by Aboriginal PersonsY N/A Y N/A N/A Y Y N N Y Y N/A YCFA and QNS&L Y N/A N N/A N/A Y Y N N Y Y N/A YAlouette AluminumSmelter ProjectSecond Port-CartierPellet PlantBloom Pointe-NoireTerminalArnaud Apatite-Magnetite mineY N/A N N/A N/A Y Y N N Y Y N/A YN N/A N N/A N/A N N N N N Y N/A YY N/A Y N/A N/A Y Y N N Y Y N/A YY N/A Y N/A N/A Y Y N N Y Y N/A YOther Current Use of Lands and ResourcesCommunity Services and InfrastructureHealth and Community HealthEconomy, Employment and BusinessKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryN/A=Cumulative effects not considered due to lack of interaction with VEC and/or addressed underassociated VECs.7.6.5 Mitigation MeasuresThe mitigation and effects management measures proposed by Alderon willmitigate the overall cumulative effect of the Project in combination with otherprojects and activities.7.6.6 Residual EffectsFor most VECs the cumulative effects of other projects and activities with the KamiTerminal were deemed not significant. Current and future activities are subject toregulatory approval processes and standard mitigation measures which would limitadverse effects. Positive cumulative effects are predicted to occur for Economy,Employment and Business.51

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary8.0 FOLLOW-UP PROGRAMA follow-up and monitoring program will be designed and conducted, asappropriate, during all phases of the Kami Terminal.The purpose of the follow-up program is to verify the accuracy of the predictionsmade in the EA as well as the effectiveness of the mitigation measures. Follow-upprograms are proposed in those cases where there is uncertainty about the effectsprediction. This uncertainty may be due to a lack of information or the nature ofthe effect, for instance if it is unique. Follow-up programs will be used to improvemitigation measures and apply adaptive management measures associated withthe Kami Terminal.52

The proposed follow-up and monitoring programs are summarized below.VECAtmosphericEnvironmentLandforms,Soils, Snow andIceWaterResourcesWetlandsFish, FishHabitat andFisheriesBirds, OtherWildlife andTheir Habitats,and ProtectedAreasSpecies at Riskand Species ofConservationConcernHistoric andCulturalResourcesCurrent Useof Lands andResources byAboriginalPersons forTraditionalPurposesOther CurrentUse of Landsand ResourcesCommunityServices andInfrastructureHealth andCommunityHealthEconomy,Employmentand BusinessCommitment• Monitoring of CO emissions from blasting near KamiTerminal site with portable monitors.• Noise monitoring.• No follow-up or monitoring required.• Monitoring of water quality of the stormwater retention pond dischargeto ensure compliance with the MDDEP Directive 019 guidelines, CCMEwater quality requirements for the protection of aquatic life andQuébec surface water criteria for the protection of aquatic life.• No follow-up or monitoring required.• No follow-up or monitoring required.• On-Site monitoring for compliance with the EPP.• On-Site monitoring for compliance with the EPP.• Adhere to all federal and provincial archaeological legislation.• On-site monitoring for compliance with the EPP.• Any follow-up and monitoring programs that have been identifiedand proposed for other VECs (particularly for the biophysicalenvironment) will be indirectly applicable to land and resource use.• Participate in air quality monitoring program initiated in Sept-Îles.• Monitor local housing indicators (vacancy rates, rental prices, sale prices, etc.).• No follow-up or monitoring required.• Promote opportunities for local and Aboriginal businesses and workers.• Promote regional subcontracting for materials and services.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary53

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary9.0 BENEFITS OF THE ENVIRONMENTALASSESSMENT TO CANADIANSIn addition to meeting regulatory requirements, this environmental assessmentprocess has resulted in various benefits to Canadians. This includes maximizedenvironmental benefits, supporting sustainable development, public participation,increases in scientific knowledge and community and social benefits. Examplesof how the environmental assessment process for the Kami Terminal benefitsCanadians is presented below.Factors of EA ProcessProviding Benefitsto CanadiansMaximizedEnvironmentalBenefitsSupportingSustainableDevelopmentPublic ParticipationIncreases in ScientificKnowledgeCommunity and SocialBenefitsCommitment• The Kami Terminal conveyor systems are covered tominimize dust generation as well as noise.• The rail loop was located adjacent to the futureConsolidated Thompson rail loop in order to minimizethe combined footprint of both infrastructure.• The length of the rail loop was minimized and locatedalmost entirely on highly artificialized port land.• The Kami Terminal is being designed and will be constructed andoperated in consideration of maximizing the future value of thefacility for eventual transfer at the end of the life of mine.• The Kami Terminal will provide workers and companieswith new experience and capabilities that will make themcompetitive for employment and business opportunities onother projects and, in some cases, other industries.• Project-related investments in infrastructure, education, training andpossibly research and development that will facilitate and fuel thesustainable economic development of the Province as a whole.• Public input has influenced the design of theProject in several major ways.• The understanding of the existing environment within andsurrounding the Kami Terminal area has been greatly improvedas a result of baseline studies conducted in support of the EA.• Local expenditures and employment will resultin community and social benefits.54

The Kami Projectwill result in positiveeffects to the localand provincialeconomy, employmentand business.10.0 OVERALL CONCLUSIONS OF THEPROPONENTThe Kami Terminal has been designed and will be undertaken to mitigate adverseenvironmental effects to acceptable levels.Concerns raised by Aboriginal groups and the public and requirements prescribedin the EIS Guidelines have been addressed by assessing the environmental effectsthat will or may result from the construction, operation and maintenance, anddecommissioning and reclamation of the Project.In summary, the Kami Terminal will not result in likelyadverse residual significant effects either in isolation orcumulatively with other projects and activities. Accidentsand malfunctions, should they occur, may result in significanteffects for some VECs. However, these effects are not likely tooccur given the planning that has been undertaken and thestandards that have been prescribed.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary55

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary11.0 REFERENCESInstitut de la Statistique du Québec (ISQ). 2011. Évolution du marché du travaildans les MRC. Décembre 2011. Available online at: www.stat.gouv.qc.ca/publications/regions/flash_regions.htm. Accessed in February 2012.Statistics Canada. 2007. 2006 Community Profiles (various tables). 2006 Census.Statistics Canada Catalogue no. 92-591-XWE. Ottawa. Released March 13,2007. Accessed 25 April 2012. Available online at: www12.statcan.ca/censusrecensement/2006/dp-pd/prof/92-591/index.cfm?Lang=EVille de Sept-Îles, 2012. Population et scène économique. Available online at :http://ville.Sept-Îles.qc.ca/main.php?sid=m&mid=81&Ing=2. Accessed June 28th,201256

Appendix AVEC Summary Tables and Residual EffectsSummary MatricesKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 57

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryTable A.1Summary of Project Residual Environmental Effects: Atmospheric EnvironmentProject PhaseMitigation / Compensation MeasuresChange in Air QualityConstruction • Use approved dust suppressantor road watering as needed.• Enforceable low speedstandards on-site.• Use drilling machineryequipped with dust collectorOperation andMaintenanceDecommissioningand Reclamationor water dust suppression.• Use CO monitors during blastingactivities at nearby receptors.• Adjust blast surface as needed.• Enclose car-dumping in buildingequipped with dust collector.• Enclosed conveyors.• Equip transfer points withdust collectors.• Design stacker to includeadjustable height.• Routine inspections of dust collectors.• Spraying water over ground surfaceto minimize wind erosion as needed.Change in GHG EmissionsConstruction • Use low CO 2hydroelectricity forinfrastructure operation.Operation andMaintenanceDecommissioningand ReclamationDirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA M L ST S R D N HA M L LT R R D N HA L S ST S R D N HA L R ST S R D L HA M R LT R R D M HA L R ST S R D L HChange in Acoustic EnvironmentConstruction • Enclosing conveyors andconveyor transfer points;A L L ST R R D N HOperation and • Proper muffler installation.Maintenance • Comprehensive and regularA L L LT C R D N HDecommissioning maintenance of vehicles.and Reclamation • Vegetation buffers by minimizing A L L ST R R D N Hthe disturbed area.Change in VibrationsConstruction • None recommendedA L S ST S R D N HOperation andMaintenanceDecommissioningand ReclamationA L S LT S R D N HA L S ST S R D N HRecommended Follow‐upand Monitoring• Monitor CO emissionsfrom blasting nearProject site withportable monitors;• Participate in air qualitymonitoring programinitiated in Sept-Îles• None recommended• None recommended• None recommendedA – 58

Project PhaseChange in Ambient Light QualityConstructionOperation andMaintenanceDecommissioningand ReclamationKey:Mitigation / Compensation Measures• Direct light where needed• Retain a vegetation screenwhere possible• Locate portable lightingequipment where not visiblein surrounding urban areas• Use of full horizontal cut offlight fixtures, as appropriateDirection:P PositiveA AdverseN NeutralMagnitude:N Negligible: no measurable adverseeffect anticipated;L Low: effect occurs that is detectablebut is within normal variability ofbaseline conditions;M Moderate: effect occurs that wouldcause an increase with regard tobaseline but is within regulatory limitsand objectives;H High: effect occurs that would singlyor as a substantial contribution incombination with other sourcescause exceedances of objectivesor standards beyond the Projectboundaries.Geographic Extent:S Site-specific: effect restricted to theProject footprint within the LSAL Local: within the LSAR Regional: within the RSAG Global: Provincial, National or Globalscale (GHG Emissions only).DirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA L S ST S R D N HA L L LT R R D N HA L S ST S R D N HDuration:Author to use quantitative measure; orST Short term: effect occurs for less thanthree yearsMT Medium term: effect occurs forbetween 3 and 15 years;LT Long-term: effect persists beyond 15yearsFrequency:Author to use quantitative measure; orO Once: effect occurs once;S Sporadic: effect occurs at sporadicintervals; intervalsR Rarely: effect occurs on a regular basisand at regular intervals; or,F Frequently: effect occurs continuouslythroughout the Project lifeReversibility:R ReversibleI IrreversibleRecommended Follow‐upand Monitoring• None recommendedEnvironmental or Socio-economic Context:U Undisturbed: Area relatively or notadversely affected by human activityD Developed: Area has beensubstantially previously disturbedby human development or humandevelopment is still presentN/A Not ApplicableSignificance:S SignificantN Not SignificantSignificance (GHG only):L less than 10 5 t CO 2eq per annumM between 10 5 t and 10 6 CO 2eq perannumH greater than 10 6 t CO 2eq per annumPrediction Confidence:Based on scientific information andstatistical analysis and effectivenessof mitigation or effects managementmeasureL Low level of confidenceM Moderate level of confidenceH High level of confidenceKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 59

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 60Table A.2Summary of Project Residual Environmental Effects: Water ResourcesProject PhaseChange in Surface Water QualityConstructionOperation andMaintenanceDecommissioningand ReclamationMitigation / Compensation Measures• Apply standard and best practicesand general environmentalprotection measures.• Use of silt fencing downstream of thework area and at the limits of the workzone to reduce the carriage of silt andfines in any water runoff from the area.• Avoid unnecessary encroachmentsin the riparian habitat oneither side of streams.• No debris will be disposed in the aquaticenvironment and any debris introducedwill be removed as soon as possible.• No earth-moving or excavation workwill be carried out near streams duringhigh water periods or heavy rains.• Use machinery that is in properoperating condition in order to avoidany oil or fuel leaks. Clean, maintainand store work site machinery andvehicles on a site designated forthis purpose at a distance of over30 m from streams and ensurean on-site supply of absorbentmaterials in case of accidental spillsas well as properly identified sealedrecipients for collecting petroleumproducts and waste materials.• Stabilize slopes as soon as possibleusing recognized bioengineeringtechniques that take into accountinstability, sensitivity to erosion, slopeand height of the embankment.• Concentrate storage area willcontain a liner in conformancewith Port requirements.• Stormwater collection in theconcentrate storage area anddrainage directed toward aretention pond with liner.• Water treatment before releaseto the environment to respectDirective 019 and ensure thatreceiving water will not exceed theCCME water quality guideline forthe protection of aquatic life.DirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA N S ST S R D/U N HA L L MT R R D/U N HA N S ST S R D/U N HRecommended Follow‐upand Monitoring• Monitoring of waterquality of the stormwaterretention pond dischargeto ensure compliance withthe MDDEP Directive 019guidelines, CCME waterquality requirements forthe protection of aquaticlife and Québec surfacewater criteria for theprotection of aquatic life.

Project PhaseMitigation / Compensation MeasuresChange in Surface Water Drainage PatternsConstruction • None requiredOperation andMaintenanceDecommissioningand ReclamationChange in Ground Water QualityConstructionOperation andMaintenanceDecommissioningand Reclamation• Apply standard and best practicesand general environmentalprotection measures.• Use machinery that is in properoperating condition in order toavoid any oil or fuel leaks.• Clean, maintain and store work sitemachinery and vehicles on a sitedesignated for this purpose at adistance of over 30 m from streamsand ensure an on-site supply ofabsorbent materials in case ofaccidental spills as well as properlyidentified sealed recipients forcollecting petroleum products and• waste materials.• Concentrate storage area willcontain a liner in conformancewith Port requirements.• Stormwater collection in theconcentrate storage area anddrainage directed toward aretention pond with liner.DirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA L L MT R R D/U N HA N S ST S R D/U N HA N S ST S R D/U N HA L L MT R R D/U N HA N S ST S R D/U N HA N S ST S R D/U N HRecommended Follow‐upand Monitoring• No monitoring required• No monitoring requiredKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 61

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryKey:Direction:P Positive: condition of the WaterResources is improving in comparisonto baseline conditions and trendsN Neutral: no change in the conditionof the Water Resources compared tobaseline conditions and trendsA Adverse: condition of Water Resourcesis worsening in comparison to baselineconditions and trendsMagnitude:N Negligible: no measurable adverseeffect anticipated;L Low: effect occurs that is detectablebut is within normal variability ofbaseline conditions;M Moderate: effect occurs that wouldcause an increase with regard tobaseline but is within regulatory limitsand objectives;H High: effect occurs that would singlyor as a substantial contribution incombination with other sourcescause exceedances of objectivesor standards beyond the Projectboundaries.Geographic Extent:S Site – within PDAL Local: within the LSAR Regional: within the RSADuration:ST Short term: effect occurs for less thanthree years;MT Medium term: effect occurs forbetween three and 20 years;LT Long-term: effect persists beyond 20years.Frequency:O Once: effect occurs once;S Sporadic: effect occurs at sporadicintervalsR Rarely: effect occurs on a regular basisCand at regular intervalsFrequently: effect occurs continuouslythroughout the Project life ContinuousReversibility:R Reversible: effect ceases when Projectoperations ceaseI Irreversible: effect continues afterProject operations cease.Environmental or Socio-economic Context:U Undisturbed: Area relatively ornot adversely affected by humanactivityD Developed: Area has beensubstantially previously disturbedby human development or humandevelopment is still presentSignificance:S SignificantN Not SignificantPrediction Confidence:Based on scientific information andstatistical analysis and effectivenessof mitigation or effects managementmeasureL Low level of confidenceM Moderate level of confidenceH High level of confidenceA – 62

Table A.3Summary of Project Residual Environmental Effects:Birds, Other Wildlife and their Habitats, and Protected AreasProject PhaseChange in HabitatConstructionChange in Distribution and MovementConstruction idemChange in Mortality RiskConstruction idemChange in HealthConstructionMitigation / Compensation Measures• Apply standard and best practicesand general environmentalprotection measures.• Environmental monitoringduring construction.• Avoid clearing during the breedingbird season, where feasible.• Develop an avifauna management plan.• Flag boundaries of sensitiveareas or buffers.• Proper muffler installation.• Comprehensive and regularmaintenance of vehicles.• Site erosion protection andsediment control measures.• Survey area for presence of sensitivewildlife prior to blasting.• Direct storm water, wastewateror surface water awayfrom wildlife habitat.• No harassment of wildlife.• Provincial and federal regulationswill be followed in the storageand handling of materials.• Implement EPP.• Implement forest fire preventionand response plan• Oil Spill Contingency planning.• Product spill contingency planningup to the proposed Port authoritycommon load-out point.• Provide employee training.idemDirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceA L S ST C I D N HA L L ST C I D N HA L L ST C I D N HA L L ST C I D N HRecommended Follow‐upand Monitoring• On-site monitoring forcompliance with the EPP.• On-site monitoring forcompliance with the EPP.• On-site monitoring forcompliance with the EPP.• On-site monitoring forcompliance with the EPP.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 63

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryKey:Direction:P PositiveA AdverseMagnitude:L Low: the residual Project (alteration /loss) are not expected to exceed 5% ofthe known population in the RSA. Nomeasurable effectM Moderate: the residual Project effects(alteration / loss) are expected to begreater than 5% and not exceed 25%of the known populations in the RSA.Effect can be measuredH High: the residual Project effects(alteration / loss) are expected toexceed 25% of the known populationin the RSA.Geographic Extent:S Site – including PDAL Local: within the LSAR Regional: within the RSADuration:STShort term - Effect occurs during thesite‐preparation or construction phaseof the Project (i.e., 1 to 2 years)MT Medium term - Effect extendsthroughout the construction andoperation phases of the Project (up to15 years)LT Long-term - Effect is greater than 15yearsPPermanent – will not change back tooriginal conditionFrequency:OSRCEffect occurs occasionally, or onceduring the life of the Project (e.g.,clearing)Occurs sporadically at irregularintervalsOccurs on a regular basis and atregular intervalsContinuousReversibility:R ReversibleI IrreversibleEnvironmental or Socio-economic Context:U Undisturbed: Area relatively or notadversely affected by human activityD Developed: Area has beensubstantially previously disturbedby human development or humandevelopment is still presentN/A Not ApplicableSignificance:S SignificantN Not SignificantPrediction Confidence:Based on scientific information andstatistical analysis and effectiveness ofmitigation or effects management measureL Low level of confidenceM Moderate level of confidenceH High level of confidenceA – 64

Table A.4Summary of Project Residual Environmental Effects:Species at Risk / Species of Conservation ConcernProject PhaseMitigation / Compensation MeasuresDirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextChange in Critical or Important HabitatConstruction • Comply with existinglegislated mitigation.• Avoid activities near or/at sensitivespecies and/or habitats, where possible.• Develop protection measures andenvironmental management techniquesbased on site-specific conditions.• Rehabilitate or restoreaffected environment.• Provide substitute resources orenvironments through seed collection/ sowing, direct transplantationor diaspore dispersal.• Provincial and federal regulationsshould be followed in the storageand handling of materials.• Implement EPP.• Provide employee training.A L S ST C I D N HChange in Distribution and MovementConstruction idemA L S ST C I D N HChange in Mortality RiskConstruction idemChange in HealthConstructionidemSignificancePrediction ConfidenceA L S ST C I D N HA L S ST C I D N HRecommended Follow‐upand Monitoring• On-site monitoring forcompliance with the EPP.• On-site monitoring forcompliance with the EPP.• On-site monitoring forcompliance with the EPP.• On-site monitoring forcompliance with the EPP.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 65

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryKey:Direction:P PositiveA AdverseMagnitude:L Low: the residual Project (alteration /loss) are not expected to exceed 5% ofthe known population in the RSA. Nomeasurable effectM Moderate: the residual Project effects(alteration / loss) are expected to begreater than 5% and not exceed 25%of the known populations in the RSA.Effect can be measuredH High: the residual Project effects(alteration / loss) are expected toexceed 25% of the known populationin the RSA.Geographic Extent:S Site – including PDAL Local: within the LSAR Regional: within the RSADuration:STShort term - Effect occurs during thesite‐preparation or construction phaseof the Project (i.e., 1 to 2 years)MT Medium term - Effect extendsthroughout the construction andoperation phases of the Project (up to15 years)LT Long-term - Effect is greater than 15yearsPPermanent – will not change back tooriginal conditionFrequency:OSRCEffect occurs occasionally, or onceduring the life of the Project (e.g.,clearing)Occurs sporadically at irregularintervalsOccurs on a regular basis and atregular intervalsContinuousReversibility:R ReversibleI IrreversibleEnvironmental or Socio-economic Context:U Undisturbed: Area relatively or notadversely affected by human activityD Developed: Area has beensubstantially previously disturbedby human development or humandevelopment is still presentN/A Not ApplicableSignificance:S SignificantN Not SignificantPrediction Confidence:Based on scientific information andstatistical analysis and effectiveness ofmitigation or effects management measureL Low level of confidenceM Moderate level of confidenceH High level of confidenceA – 66

Table A.5Summary of Project Residual Environmental Effects: Historic and Cultural ResourcesProject PhaseMitigation / Compensation MeasuresDisturbance or Loss of Archaeological Sites or MaterialsConstruction • Implement EPP in the event ofan unexpected discovery.Operation andMaintenanceDecommissioningand ReclamationKey:Direction:P PositiveA AdverseMagnitude:N No Effect: - no likely effectL Low: disturbance but with priorretrieval of the resource andassociated information, and with allnecessary regulatory approvalsM Moderate disturbance or loss of all ora portion, with retrieval of a portionof the resource and its associatedinformation, or a direct effect on aknown Historic and Cultural Resource,which is of interest and concern to theassociated community, but which doesnot reduce the overall integrity andcultural value of the siteH High: disturbance or loss, with noretrieval of the resource and itsassociated information, or a directeffect on a Historic and CulturalResource, which reduces the overallintegrity and cultural value of the site.DirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceRecommended Follow‐upand MonitoringAAAN/LN/LN/LSSSPPPSSSU/DU/DU/DNNNHHHMMM• Adhere to all federal andprovincial archaeologicallegislation.• On-site monitoring forcompliance with the EPP.Geographic Extent:S Site – including PDA and 200 mbeyondL Local: within the LSAR Regional: within the RSADuration:ST Short termMT Medium termLT Long-termP Permanent – will not change back tooriginal conditionFrequency:O Occasionally, once per month or lessS Occurs sporadically at irregularintervalsR Occurs on a regular basis and atregular intervalsC ContinuousEnvironmental or Socio-economic Context:U Undisturbed: Area relatively or notadversely affected by human activityD Developed: Area has beensubstantially previously disturbedby human development or humandevelopment is still presentN/A Not ApplicableSignificance:S SignificantN Not SignificantPrediction Confidence:Based on scientific information andstatistical analysis and effectiveness ofmitigation or effects management measureL Low level of confidenceM Moderate level of confidenceH High level of confidenceKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 67

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryTable A.6Summary of Project Residual Environmental Effects: Current Use of Landand Resources for Traditional Purposes by Aboriginal PersonsProject PhaseMitigation / Compensation MeasuresChange in Activity Distribution (Location and/or Timing)Construction • The design and siting of the Québecterminal facility (concentrate storageand loadout facility and rail loop)within an existing industrial area.Operation and • On-going engagement with AboriginalMaintenance communities and organizations.• Possible work rotations / cultural leaveprovisions for Aboriginal employeesDecommissioningand ReclamationDirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceN - - N - - D N HN - - N - - D N HN - - N - - D N HChange in Overall Activity LevelsConstruction • The design and siting of the Québecterminal facility (concentrate storageand loadout facility and rail loop)N - - N - - D N HOperation andMaintenanceDecommissioningand Reclamationwithin an existing industrial area.• On-going engagement with Aboriginalcommunities and organizations• Possible work rotations / cultural leaveprovisions for Aboriginal employeesNN----NN----DDNNHHResulting Change in Overall Quality and Cultural Value of the ActivityConstruction • The design and siting of the Québecterminal facility (concentrate storageand loadout facility and rail loop)N - - N - - D N HOperation andMaintenancewithin an existing industrial area.• On-going engagement with Aboriginalcommunities and organizations.N - - N - - D N HDecommissioningand Reclamation N - - N - - D N HRecommended Follow‐upand Monitoring• Any follow-up andmonitoring programsthat have been identifiedand proposed for otherVECs (particularly for thebiophysical environment)will be indirectly applicableto land and resource use.On-going engagement withAboriginal communitiesand organizations.• Any follow-up andmonitoring programsthat have been identifiedand proposed for otherVECs (particularly for thebiophysical environment)will be indirectly applicableto land and resource use.• Any follow-up andmonitoring programsthat have been identifiedand proposed for otherVECs (particularly for thebiophysical environment)will be indirectly applicableto land and resource use.A – 68

Key:Direction:P PositiveA AdverseN Neutral (or No Effect)Magnitude:L Low: affects a small group of usersM Moderate: affects less than themajority of users across multipleactivitiesH High: affects the majority of landand resource users across multipleactivitiesGeographic Extent:S Site: includes PDA and 200 m beyondL Local: LSAR Regional: RSAFrequency:N Not likely to occurO Once: Occurs onceS Sporadic: occurs sporadicallyR Regular: occurs on a regular basisC ContinuousDuration:S Short term: construction phase onlyM Medium term: continues throughoperation and maintenance phaseL Long-term: continues beyondoperation and maintenanceP PermanentReversibility:R ReversibleI IrreversibleEnvironmental or Socio-economic Context:U Undisturbed: Area relatively or notadversely affected by human activityD Developed: Area has beensubstantially previously disturbedby human development or humandevelopment is still presentSignificance:S SignificantN Not SignificantPrediction Confidence:Based on scientific information andstatistical analysis and effectiveness ofmitigation or effects management measureL Low level of confidenceM Moderate level of confidenceH High level of confidenceN/A Not ApplicableKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 69

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryTable A.7Summary of Project Residual Environmental Effects: Other Current Use of Land and ResourcesProject PhaseMitigation / Compensation MeasuresDirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextChanges to Industrial DevelopmentConstruction • Realign access road and watermain and stockpile rocks toA L S ST O R D N Hminimize effects on the AluminerieOperation andAlouette aluminum smelter.Maintenance A L S LT O R D N HDecommissioningand ReclamationChanges to Residential and Recreational PropertyConstruction • Proper muffler installation.• Comprehensive vehicle andmachinery maintenance program.• Enforceable low-speedstandards on-site.Operation and • Blast design plansMaintenance• Use of full horizontal cutoff light fixtures.• Locate lateral lighting fixturesDecommissioningon south side of facility.and Reclamation• Direct lateral lighting awayfrom the baie des Sept-Îles.• Enclose conveyor transfer points.• Vegetation buffers.SignificancePrediction ConfidenceA L S ST O R D N HA L L LT S R D N HA L L LT S R D N HA L S ST O R D N HRecommended Follow‐upand Monitoring• No monitoring required.• Participate in air qualitymonitoring programinitiated in Sept-Îles.A – 70

Key:Direction:B Beneficial - condition of other currentuse of land and resources is improvedin comparison to baseline conditionsand trendsN Neutral - no change in the conditionof other current use of land andresources compared to baselineconditions and trends,A Adverse - condition of other currentuse of land and resources is worsenedin comparison to baseline conditionsand trendsMagnitude:L Low - affects a small group of land andresource usersM Moderate - affects less than themajority of land and resource usersacross multiple activitiesH High - affects the majority of landand resource users across multipleactivitiesGeographic Extent:S Site-specific – effect restricted to theProject footprint within the LSAL Local - effect restricted to within theLSAR Regional - effect extends beyond theLSA but is within the RSADuration:ST Short term – effect occurs for less thanthree yearsMT Medium term – effect occurs for thelife of the ProjectLT Long-term – effect persists beyond thelife of the ProjectP Permanent – will not change back tooriginal condition.Frequency:O Occasionally, once per month or lessS Occurs sporadically at irregularintervals.R Occurs on a regular basis and atregular intervals.C Continuous.Reversibility:R Reversible – effect ceases whenProject operations ceaseI Irreversible – effect continues afterProject operations ceaseEnvironmental and Socio-economicContext:U Undisturbed - Area relatively or notadversely affected by human activityD Developed - Area has beensubstantially previously disturbedby human development or humandevelopment is still presentN/A Not Applicable.Significance:S SignificantN Not Significant.Prediction Confidence:Based on scientific information andstatistical analysis and effectiveness ofmitigation or effects management measureL Low level of confidenceM Moderate level of confidenceH High level of confidence.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 71

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryTable A.8Summary of Project Residual Environmental Effects: Community Services and InfrastructureProject PhaseMitigation / Compensation MeasuresChange to Housing SupplyConstruction • Engage with local authorities andother stakeholders to address issuesOperation and related to community servicesMaintenance and infrastructure as needed.Decommissioningand ReclamationChange to Traffic ConditionsConstruction • Engage with local authorities andother stakeholders to address issuesOperation and related to community servicesMaintenance and infrastructure as needed.Decommissioningand ReclamationKey:Direction:P PositiveA AdverseMagnitude:L Low proportion of local or regionalpopulation that is affectedM Moderate proportion of local orregional population that is affectedH High proportion of local or regionalpopulation that is affected.Geographic Extent:S Site – including PDA and 200 mbeyondL Local: within the LSAR Regional: within the RSADirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceRecommended Follow‐upand MonitoringA L R ST C R N/A N H • Monitor local housingA L R LT C R N/A N Hindicators (vacancyrates, rental prices,A L R ST C R N/A N Hsales prices, etc.)A L L ST C R N/A N HA L L LT C R N/A N HA L L LT C R N/A N HDuration:ST Short termMT Medium termLT Long-termP Permanent – will not change back tooriginal condition.Frequency:O Occasionally, once per month or lessS Occurs sporadically at irregularintervals.R Occurs on a regular basis and atregular intervals.C Continuous.Reversibility:R ReversibleI Irreversible• No monitoring required.Environmental Context:U Undisturbed: Area relatively or notadversely affected by human activityD Developed: Area has beensubstantially previously disturbedby human development or humandevelopment is still presentN/A Not Applicable.Significance:S SignificantN Not Significant.Prediction Confidence:Based on scientific information andstatistical analysis and effectiveness ofmitigation or effects management measureL Low level of confidenceM Moderate level of confidenceH High level of confidenceA – 72

Table A.9Summary of Project Residual Environmental Effects: Economy, Employment and BusinessProject PhaseChange to Regional EmploymentConstructionOperation andMaintenanceDecommissioningand ReclamationMitigation / Compensation Measures• Collaborate with the Regionaleconomic forum• Promote regional subcontractingfor materials and services• Promote opportunities for local andAboriginal businesses and workersDirectionMagnitudeResidual EnvironmentalEffects CharacteristicsGeographic ExtentDurationFrequencyReversibilityEnvironmental or Socio-Economic ContextSignificancePrediction ConfidenceP H R ST C N/A N/A S HP L R LT C N/A N/A N HP L R ST C N/A N/A N HChange to Regional BusinessesConstruction • Collaborate with the Regionaleconomic forum• Promote regional subcontractingOperation and for materials and servicesMaintenance P H R LT C N/A N/A S H• Promote opportunities for local andDecommissioning Aboriginal businesses and workersand Reclamation • Coordinate disruptions to utilities and P L R ST C N/A N/A N Hinfrastructure to minimize effectsKey:Direction:P PositiveA AdverseMagnitude:No effect - no detectable effect anticipatedon economic conditionsL Low - detectable effect occurs oneconomic activity, but is within normalvariability of baseline conditionsM Moderate - effect occurs thatrepresents a relative increase ineconomic activity with regard tobaseline conditionsH High - effect occurs that singly oras a substantial contribution incombination with other sourcesrepresents a significant increase ineconomic activity with regard tobaseline conditions.Geographic Extent:S Site - including PDA and 200 m beyondL Local - within the LSAR Regional - within the RSARecommended Follow‐upand Monitoring• Promote opportunitiesfor local and Aboriginalbusinesses and workers.P H R ST C N/A N/A S H • Promote opportunitiesfor local and AboriginalDuration:ST Short term - effect occurs for less thanthree yearsMT Medium term - effect occurs for thelife of the ProjectLT Long-term - effect persists beyond thelife of the ProjectP Permanent – will not change back tooriginal condition.Frequency:O Occasionally, once per month or lessS Occurs sporadically at irregularintervals.R Occurs on a regular basis and atregular intervals.C Continuous.Reversibility:R ReversibleI IrreversibleN/A Not Applicablebusinesses and workers.• Promote regionalsubcontracting formaterials and services.Environmental Context:U Undisturbed: Area relatively or notadversely affected by human activityD Developed: Area has beensubstantially previously disturbedby human development or humandevelopment is still presentN/A Not ApplicableSignificance:S SignificantN Not SignificantPrediction Confidence:Based on scientific information andstatistical analysis and effectiveness ofmitigation or effects management measureL Low level of confidenceM Moderate level of confidenceH High level of confidenceKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryA – 73

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APPENDIX BComplete Record of all CommentsIdentified During Consultation andEngagement Activities with ResponsesKami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 75

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Table B.1Atmospheric EnvironmentIssue CommunitySummary of comments raised duringconsultation and engagement activitiesDust Sept-Îles Two residents enquired about dust emissionsassociated to rail car dumpersCumulativeimpacts of multipleindustries on airqualitySept-ÎlesSept-ÎlesSept-ÎlesSept-ÎlesOne resident enquired about dust emissionsassociated to rock cuttingTwo residents enquired about dust emissionsassociated to the loading of boatsTwo residents asked what mitigation measureswere planned to control fugitive dust from theconcentrate stockpileOne resident indicated its concern aboutcumulative effects, due to the presence ofother industries. A reference to an air qualitycommittee was made, by indicating that it hasyet to decide where to install its air qualitymonitors.Another resident asked if Alderon is installing airquality monitors in Sept-Îles.Response / Location in EISRail cars will be emptied inside a building, andemissions will be treated by a dust collector.More information is available in Section 14.6.Effects of dust emissions associated to theconstruction will be short-term and activitieswill be carried out according to constructionstandards and industry best practices. Moreinformation is available in Section 14.6.Product loading of ships will be managed by thePort, which will comply with all applicable lawsand regulations.Measures to control fugitive dust at theconcentrate stockpile include adjusting theheight of the stacker- reclaimer, and use of wateras and when needed. Additional information isprovided in Section 14.6.Alderon will participate to the air qualitymonitoring effort initiated in Sept-Îles. Additionaldetails are available in Section 14.6.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 77

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryTable B.2Water ResourcesIssuePotentialcontamination ofwater bodiesCommunitySept-ÎlesSummary of comments raised duringconsultation and engagement activitiesMany companies have discharged directly intothe bay. Want to ensure that this project will notcarry out the same practice.What measures would be used to avoidcontamination of Sept-Îles Bay by red water?Water quality Sept-Îles Resident inquired whether Alderon had testedthe quality of water in Sept-Îles Bay. Askedif Alderon will treat water in order to meetstandards and regulations or to maintain waterquality at its present level.Cumulative effectson water resourcesCREPotential effects on water quality in the baie desSept-ÎlesThere is a lot of pressure around the Bay,concerned about cumulative effects. It would begreat if elements of the Kami Project could belocated further to the shore.Response / Location in EISIn order to prevent water contamination, theconcentrate storage area, will be sealed withliner. Water run-off within the concentratestorage area will be directed toward astormwater retention pond (with liner)where it will be treated before release to theenvironment. Final effluent treatment will meetor surpass Directive 019 criteria and will ensurethat receiving water within the effluent mixingzone will not exceed the applicable CCME waterquality guideline for the protection of aquaticlife. More information can be found in Section16.6.Water quality in baie des Sept-Îles (anse Brochu)was analyzed for several parameters. Moreinformation can be found in Section 16.5.Final effluent treatment will meet or surpassDirective 019 criteria and will ensure thatreceiving water within the effluent mixing zonewill not exceed the applicable CCME waterquality guideline for the protection of aquaticlife. More information can be found in Section16.6.Product loading of ships will be managed by thePort, which will comply with all applicable lawsand regulations.Alderon assessed several alternatives whenchoosing a site for the Terminal. The selectedsite was the most economically and technicallyfeasible. More information regarding siteselection can be found in Section 2.8. Alderonwill minimize its influence on the baie desSept-Îles including treatment of final effluenttreatment will meet or surpass standards. Moreinformation can be found in Section 16.6.B – 78

Table B.3Freshwater Fish, Fish Habitat, and FisheriesIssueCumulative effectson fish and fishhabitatCommunityCRE/CPESISummary of comments raised duringconsultation and engagement activitiesResponse / Location in EISThere is a lot of pressure around the Bay, Alderon assessed several alternatives whenconcerned about cumulative effects. It would be choosing a site for the Terminal. The selectedgreat if elements of the Kami Project could be site was the most economically and technicallylocated further to the shore.feasible. More information regarding siteselection can be found in Section 2.8. Alderonwill minimize its influence on the baie desSept-Îles including treatment of final effluenttreatment will meet or surpass standards. Moreinformation can be found in Section 16.6.Fish population Sept-Îles Resident asked about the potential effects of theproject on fish in ruisseau à la Baleine.Fish habitat Sept-Îles Resident voiced concern about impact ofincreasing rail traffic on the Nipississ River,particularly its effect on salmon spawninggrounds. Discussed how the vibrations from therail traffic would destroy salmon spawning.Table B.4WetlandIssue CommunitySummary of comments raised duringconsultation and engagement activitiesWetlands Sept-Îles There is a protected wetland in the Pointe-NoireareaTable B.5Birds, Other Wildlife and Their HabitatsIssueParks andprotected areasPotential effects onwildlife speciesIn response to concerns raised regarding thepresence of fish at the Terminal site, Alderonconducted a fish and fish habitat survey. Thefindings of this survey are provided in Chapter18.Rail operations in the vicinity of the NipississRiver are beyond the scope of the Project. Thisactivity is the mandate of the QNS&L Railwayand all operations are required to comply withall applicable provincial and federal regulationsregarding fish and fish habitat.Response / Location in EISNo wetland was identified in the ProjectDevelopment Area at the Kami Terminal.Information is available in Chapter 17.CommunitySummary of comments raised duringconsultation and engagement activitiesResponse / Location in EISSept-Îles There is a protected wetland in the area. The Kami Terminal does not overlap with anyprotected or designated areas. The assessmentof the Project on protected areas is provided inSection 19.6.CREThe baie des Sept-Îles is an importantAlderon conducted dispersion modelling forconservation zone for migratory birds and the Kami Terminal, the results of which indicateconcerned about the potential effects of the that no substantive changes in air quality aredust generated from the project on the bay. expected on local or regional scales due toemissions from the Project. in the modellingSept-ÎlesResident raised issue of migratory birds and birdspecies at riskresults are presented in Section 19.4.2As part of the EIS, field surveys were conductedto identify habitat and species potentiallyaffected by the Kami Terminal. These surveysdid not identify any rare or unique habitats thatwill be affected by the Kami Terminal. Additionalinformation on bird species, including migratorybirds, is provided in Section 19.5.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 79

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryTable B.6Species at RiskIssuePotential effectson SARCommunitySept-ÎlesTable B.7Aboriginal Land UseIssuePotentialinteraction withexisting Aboriginalrights/titleTable B.8Other Land UseCommunityUashatSummary of comments raised duringconsultation and engagement activitiesResident raised issue of migratory birds and birdSARResponse / Location in EISIn response to concerns related to the presenceof bird species, including migratory species, atthe Kami Terminal, field surveys were conductedto identify species presence. Although the KamiTerminal site does overlap with the geographicrange of some bird species at risk, the fieldsurveys did not identify any rare bird speciesin the vicinity of the Kami Terminal. Additionalinformation on the distribution of bird speciesat risk, including migratory birds, is provided inSection 20.5.Summary of comments raised duringconsultation and engagement activitiesResponse / Location in EISUashat do not consider themselves as Québec Alderon has been engaged with AboriginalInnu and they want to be involved in the entire groups on an ongoing basis on the Project as aProject, and not only the Québec components in whole (mine site, port infrastructure). Alderonthe Port of Sept-Îles.will continue to engage Aboriginal groupsthroughout the life of the Project.Issue CommunitySummary of comments raised duringconsultation and engagement activitiesVisual Aesthetics Sept-Îles Visual effects of the port facilities, includingstockpileInformation on Aboriginal engagement isprovided in Section 10.2.Response / Location in EISNo impacts on visual aesthetics (viewscapes)are anticipated for residential areas of Sept-Îles as they are located on the opposite side ofthe Bay from the Kami Terminal, at a distanceof approximately 7 km. They will representa minimal visual change from other existingindustrial port facilities.Additional information can be found in Sections23.4 and 23.6B – 80

Table B.9Community Services and InfrastructureIssueCumulative effecton communityservices andinfrastructureAvailability of Sept-Îleshousing for workersCommunitySummary of comments raised duringconsultation and engagement activitiesResponse / Location in EISCRE Cumulative socio-economic effects Construction activities associated with theTerminal site will require a workforce in the orderof 200 to 300 workers over the next few years.Cumulative effects on the housing market and ontraffic congestion are considered to be shorttermand will be significant. The assessment ofcumulative effects on Community Services andInfrastructure is provided in Section 24.7.CIM Conference Aren’t you concerned that the QNS&L railway is The capacity of the QNS&L has been studied forbecoming over utilized?many different potential future traffic volumes,both with and without the proposed Alderontraffic. Infrastructure improvement strategieshave been identified from these studies thatwill maintain acceptable levels of service forall traffic on QNS&L and these strategies havebeen incorporated into the negotiations for a railCREResident asked where people working on thisproject would be housed. Followed up withconcerns about repercussions on housing in thecommunity. Asked if accommodations will bebuilt to lodge the workers.Noting that housing is an issue, a residentoutlined a number of initiatives that have beencompleted or are being planned to deal with theincrease in the housing demand.Access to housing and service industry in Sept-Îles during construction of port facilities.Railway traffic Labrador City The actual railway line and its railway are issuesof concern. Has Alderon consulted with QNS&Labout the projected total rail traffic in 2015-2020?M-LJIncreased traffic from the Project may slowdown the passenger train and delivery of goods(food and fuel) from Sept-Îles to Scheffervillehaulage contract.In order to manage the impact of Kami Terminalconstruction activities on regional housing supplyAlderon will engage with local authorities andother stakeholders to address issues relatedto community services and infrastructure asneeded. The assessment of Kami Terminal effectson housing is available in Section 24.6.The capacity of the QNS&L has been studied formany different potential future traffic volumes,both with and without the proposed Alderontraffic. Infrastructure improvement strategieshave been identified from these studies thatwill maintain acceptable levels of service forall traffic on QNS&L and these strategies havebeen incorporated into the negotiations for a railhaulage contract.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryB – 81

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryIssueCommunityservicesCommunitySept-ÎlesCRESummary of comments raised duringconsultation and engagement activitiesResident talked about issues with communityservicesAccess to housing and service industry in Sept-Îles during construction of port facilities.Response / Location in EISIn order to manage the impact of Kami Terminalconstruction activities on regional housing supplyAlderon will engage with local authorities andother stakeholders to address issues relatedto community services and infrastructure asneeded. By virtue of the characteristics of therequired workforce, it is considered unlikelythat these workers would exert additionaldemand on local employment and socialservices, health services and social programs,training and education services and programs,public safety and security services, municipaladministrative capacity, or municipal servicesand infrastructure.The assessment of Kami Terminal effects oncommunity infrastructure and services isavailable in Section 24.6.In order to manage the impact of Kami Terminalconstruction activities on regional housing supplyAlderon will engage with local authorities andother stakeholders to address issues relatedto community services and infrastructure asneeded. The assessment of Kami Terminal effectson housing are available in Section 24.6.B – 82

Table B.10Economy, Employment and BusinessIssueCumulative effectsto economy,employment andbusinessApprenticeship andTrainingAvailability of localworkersLocal businessesCommunitySummary of comments raised duringconsultation and engagement activitiesResponse / Location in EISCRE Cumulative socio-economic effects Construction activities resulting from variousProjects in the area will require an overallworkforce in the order of 2,000 to 3,000 workersover the next few years as well as hundreds ofadditional employees over the life of severalprojects. Regional businesses are likely to benefitfrom contracts for materials and services bothin the short-term and the long-term. Additionalinformation on cumulative effects to economy,employment and business is provided in Section26.10.The Mayor suggested that Alderon contact theEducation/Training institutions in the regionAre you going to use local workers foroperations or go FIFO?CIM Conference Many indications of interest by regionalsuppliers and contractors. In this regards, Ibelieve we should hold information forums inSt. John’s and Sept-Îles when our contractingstrategy is firmed up.Sept-Îles Involvement of the local communities andbusinesses in the procurement process for theconstruction and operation of the mine.Alderon is committed to build and maintainpositive and long-term relationship withstakeholders. Alderon will engage with allinterested parties. Additional information onconsultation completed to-date is provided inChapter 10.Alderon is committed to promoting regionalsubcontracting and employment, includinglocal and Aboriginal opportunities. In addition,Alderon will collaborate with the regionaleconomic forum to maximize local employment.Section 26.6 contains the assessment of KamiTerminal effects on employment and business.Alderon is committed to promoting regionalsubcontracting and employment, includinglocal and Aboriginal opportunities. In addition,Alderon will collaborate with the regionaleconomic forum to maximize local employment.Section 26.6 contains the assessment of KamiTerminal effects on employment and business.Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language SummaryPotential effects onlocal economySept-ÎlesState the company’s intentions concerning localprocurementThe Mayor suggested that Alderon contact theCLD which is an entity that supports small andmedium size businesses. He also suggestedAlderon contact the local Chamber of Commerceand offers to speak at one of their functions. Healso recommended a meeting with the Sept-ÎlesEconomic Development Agency that looks aftermajor industries.At the end of the predicted mine life, what areyou going to do with your employees?As outlined in its Community Relations Policy,Alderon is committed to build and maintainpositive and long-term relationship withstakeholders. Alderon will engage with allinterested parties. Alderon will collaboratewith the Regional economic forum. Additionalinformation on consultation is provided inChapter 10.The workforce will be kept informed of Projectplans and, as with any other project, will bedown-sized as the Project plans warrant.B – 83

Kami Iron Ore Project Environmental Impact Statement ‐– Plain Language Summary(this page is deliberately blank, for layout purposes)10 Fort William Place, 8th FloorSt. John’s, NL A1C 5W2B – 84Tel: (709) 576-5607Fax: (709) 576-7541