Question: The proponent's operational plan, as illustrated in Fig. 2.3.1. indicates that WC I, approx. 100 meters of WC 3, and a portion of a wetland (WL 3) will be destroyed by quarry operations. During the initial public meeting, I discussed the necessity of this destruction with the EIA's signatory, Mr. Denis Marquis. My stated concern was regarding the necessity of destroying the above mentioned features, when avoidance would likely only reduce the operational area by approx. 4 ha. The response I received was that, even with the maintenance of a 60 meter buffer along these features, given the nature of the operation, they would ultimately be destroyed anyway. The proponent has not offered any specific geotechnical information in the EIA, such as detailed contours, soil profiles, core sample results, etc., which would technically support this "assumption of destruction", even if standard setbacks were adhered to. I see no direct statement or indication in the EIA document itself which delineates the area or zone of inevitable destruction of wetland / watercourse features. It should be noted that all field identified wetland drainage connections identified within the PDA flow towards the eastern boundary (WC3 / WL 3) as opposed to toward the intended pit. It should be further noted that in SEC. 5.5.3.1., the proponent states that "no regulated wetlands are located within the PDA, nor is it expected that they will be directly affected by the project". Given that the regulated wetland identified on the northeast boundary (Fig. 2.3.1.) is immediately adjacent to the proposed pit boundary (well within 60 m), this would absolutely contradict the proponent's logic that WL 1, WL 3, and WC 3 would be destroyed by quarry activities outside of the 60 m. buffer. One or the other of these assumptions must therefore be incorrect....

Thank you for pointing out this potential for misunderstanding in the EIA Registration; the statements appearing in the document in this regard are factually correct. Below are the facts for clarification:

  1. There are no regulated (i.e., mapped) wetlands on the Project site—only 13 unregulated (unmapped) wetlands.
  2. There is a regulated (mapped) wetland on the neighbouring property to the northeast of the Project site.
  3. The 13 unmapped wetlands located on the Project site were field delineated and their functions evaluated in 2018 for the purpose of the EIA Registration since most of them (11 of 13) will be directly lost to make way for the Project components (i.e., they will be disturbed by earth moving and operational activities on the site, and their footprint will be covered by Project components such as the open pit, the storage pad, and other facilities).
  4. Wetlands WL8 and WL9 on the Project site will not be lost due to the Project since the Project components in those areas can be sited to avoid their disturbance.
  5. Wetland WL3, located on the northeast corner of the Project site, is hydraulically connected (via watercourse WC1) to the mapped wetland located on the neighbouring property to the northeast of the Project site, but WL3 is not a mapped wetland. WL3 will be directly lost due to development of the open pit over this wetland.
  6. The mapped wetland located on the neighbouring property to the northeast of the Project site will not be directly lost to Project facilities (i.e., its footprint will not be lost to Project components). However, it is highly likely that this mapped wetland will experience indirect loss of wetland function due to seepage of the water it contains into the open pit (i.e., an excavation below surrounding ground elevation that effectively acts as a groundwater “sink”). This assumption has not yet been substantiated and the only way to confirm or refute it is through monitoring and adaptive management during operation of the Project, but assuming that it will be lost is a conservative assumption that is relatively standard in Project EIA.

Hammond River Holdings will monitor, and attempt to mitigate, the indirect loss of wetland function to the mapped wetland on the neighbouring property to the northeast of the Project site to the extent possible through adaptive management. Mitigation measures may include the construction of a small berm in an attempt to preserve flow in watercourse WC1.

Finally, it should be noted that, for the purposes of the EIA Registration, only the 13 unmapped wetlands located on the Project site were field delineated in 2018. It was not possible to delineate the mapped wetland on the neighbouring property to the northeast of the Project site since it is located on a private property that is not owned by Hammond River Holdings, and to do so would have resulted in illegal trespassing on private land. Should the landowner of that property provide permission to access the property for this purpose in the future, Hammond River Holdings will delineate and evaluate the function of this wetland prior to construction so as to serve as a baseline for monitoring future indirect effects on this wetland.