GISCOME QUARRY AND LIME PLANT PROJECT

ASSESSMENT REPORT

With respect to:

the Application by Graymont Western Canada Inc.

for an Environmental Assessment Certificate

pursuant to the Environmental Assessment Act, S.B.C. 2002, c.43

Prepared by:

Environmental Assessment Office

November 23, 2016

1. Introduction
This report provides an overview of the environmental assessment (EA) for the
proposed Giscome Quarry and Lime Plant Project (Giscome Project) conducted by the
Environmental Assessment Office (EAO). It summarizes the procedures followed during
the EA and the findings of the EA, and cross-references relevant sections of EAO’s
Giscome Project Technical Report (Technical Report) where more in-depth analysis and
discussion can be found.

2. Project Description
Proponent Description

Graymont Western Canada Inc. (Graymont) is a supplier of lime and limestone products
based in Richmond, British Columbia (BC). Graymont serves major markets throughout
the United States and Canada, and the Asia-Pacific region. Graymont’s lime operations
are focused on the production of high calcium and dolomitic lime and value-added
lime-based products such as hydrated lime and precipitated calcium carbonate as well
as pulverized limestone and construction stone.

Project Description and Scope

Graymont has proposed to develop a limestone quarry and lime-processing facility near
the Village of Giscome, BC, located approximately 27 kilometres (km) east-northeast of
Prince George, BC. The rate of limestone extraction would initially be up to
approximately 600,000 tonnes per year, with a future potential limestone extraction rate
of up to 1.7 million tonnes per year. The quarry and lime processing plant would be
connected by an overland conveyor, which would be used to transport the limestone to
the plant site for processing. Graymont is proposing to develop the Giscome Project in
phases. The first phase would include quarry development, construction of the overland
conveyor and the lime processing plant, likely initially with one lime kiln. Second and
third kilns would be constructed when market conditions support the additional volume.
The rate of lime production would initially be approximately 200,000 tonnes per year,
with a potential annual lime production rate of 600,000 tonnes from three kilns.

Project Components and Location

The proposed lime processing plant is located on private land owned by Graymont,
approximately 1 km east-northeast of the Village of Giscome. An existing adjacent
Canadian National (CN) rail line would be the main form of access to receive solid fuels,
if required, and to ship lime offsite. Road access to the Giscome Project would be along
a currently existing road which connects to the south edge of the proposed plant area.

The proposed quarry is located on Crown land, approximately 4 km southeast of the

Village of Giscome. Limestone extracted from the quarry would be transported to the
processing plant by a 4.3 km long overland conveyor. The proposed limestone quarry

1
would be accessed by Bateman Creek Road, an existing access road as well as via a
new service road which would parallel the proposed overland conveyor.

The quarry pit would eventually cover an area of approximately 40 hectares. The final
dimensions of the open pit would be approximately 1,000 metres (m) in the east-west
direction and approximately 450 m in the north-south direction; with an overall depth of
up to 110 m. Associated quarry infrastructure includes a limestone crusher and
screening facility, sediment ponds, limestone and soil stockpiles.

The Giscome Project is located within the asserted traditional territory of the Lheidli
T’enneh First Nation (LTFN).

Figure 1 : Map of the Giscome Project area and layout

In the event an Environmental Assessment Certificate (EAC) is issued, and Graymont

receives additional necessary permits and approvals, it is anticipated that construction
may begin in the spring of 2018. Construction and commissioning would be completed
in 2021 and commercial operations commence at that time. It is expected that the
Giscome Project would operate for at least 50 years.

3. Environmental Assessment Process

In conducting this EA, EAO considered the potential environmental, social, heritage and
health effects, including cumulative effects, of the Giscome Project under the

2
Environmental Assessment Act (Act). An assessment of the economic effects was not
undertaken as it was determined that the potential for adverse effects for this
component were low.

EAO conducted the EA in consultation with an advisory working group made up of

provincial, local government and LTFN representatives with the mandates and skill sets
relevant to the valued components assessed as part of the review of the Giscome
Project.

EAO undertook public consultation activities during the course of the EA, including
holding two public comment periods (PCP) and one open house during Application
Review. All public comments, and Graymont’s responses to these comments, were
considered and addressed in completing the EA.

On April 12, 2007, EAO determined that the Giscome Project was reviewable pursuant
to the Reviewable Projects Regulation (i.e. a production capacity greater than or equal
to 250,000 tonnes/year), and issued an Order under Section 10 of the Act. The
Giscome Project would not require a federal EA. After the Section 10 Order was issued,
Graymont put the Giscome Project on hold due to economic reasons.

On February 27, 2014, EAO issued an Order under Section 11 of the Act, which set out
the scope, procedures and methods for the EA.

EAO required Graymont to develop a Valued Components (VCs) Selection Document

which was provided for review by the Working Group and LTFN. The VCs, and the
information that must be collected, analyzed and presented by Graymont in their
Application for an EAC (Application), were identified by Graymont in the draft
Application Information Requirements (AIR). A PCP was held on the draft AIR from
August 8, 2014, to September 8, 2014. After Graymont responded to the public
comments, the Working Group reviewed the draft AIR and on September 22, 2014,
EAO issued the final AIR for the Giscome Project.

The Application Review Stage of the EA started on November 23, 2015, following a
30-day evaluation of the Application against the AIR by EAO and the Working Group.
The Working Group and public provided additional review and comments on the
Application and supplementary material during the Application Review Stage.

EAO completed the review of the Giscome Project and on November 23, 2016, referred
the Application for decision to the Minister of Environment and Minister of Energy and
Mines.

Other Required Authorizations

If an EAC is issued, the Giscome Project would also require various permits from
provincial and local governments and possibly an authorization from Fisheries and
Oceans Canada (DFO). The majority of provincial permits would be issued through the

3
Ministry of Energy and Mines (MEM), the Ministry of Environment (MoE), and the
Ministry of Forests, Lands and Natural Resource Operations (FLNRO).

The Giscome Project is currently undergoing a synchronous permitting process through

a Mine Review Committee that is managed by MEM.

As there is the potential to destroy and alter fish habitat by displacing 570m2 of non-fish
bearing aquatic habitat in the Bateman Creek watershed, or the equivalent of 0.5% of
instream habitat within the LSA, EAO has proposed Condition 14 to ensure that a fish
and fish habitat plan will be prepared in consultation with LTFN, FNLRO, MoE and
MEM. Graymont has applied for an authorization from DFO to carry out any proposed
work, undertaking, or activity that could cause serious harm to fish, under the
subsection 35(2) of the Fisheries Act. EAO understands that Graymont will continue to
work through the DFO authorization process independent of the conclusion of the EA.

4. Key Conclusions of the Environmental Assessment

EAs in BC use VCs as an organizing framework for the assessment of the potential
effects for proposed projects. VCs are components of the natural and human
environment that are considered by Graymont, the public, Aboriginal groups, scientists
and other technical specialists, and government agencies involved in the EA process to
have scientific, ecological, economic, social, cultural, archaeological, historical or other
importance. To ensure effective use of resources and appropriately focus on the
potential for significant adverse effects, EAO selects VCs that evaluate the
project-environment interactions of the greatest importance and consequence.

EAO’s Technical Report is organized around the selected VCs:

Wildlife and Wildlife Habitat (Section 2);

Aquatic Resources (Section 3);
Greenhouse Gas Emissions (Section 4);
Recreation (Section 5.1);
Visual Aesthetics (Section 5.1);
Heritage (Section 6.0);
Air Quality (Section 7.1); and
Acoustic Environment (Section 7.2).

EAO’s Technical Report assesses the impacts of the Giscome Project on all VCs listed
above, identifies key mitigation measures for each, and reaches conclusions on their
residual effects. To ensure the effects of the Giscome Project are sufficiently mitigated,
EAO proposes 25 conditions to be included in the EAC, if issued, along with a Certified
Project Description (CPD). Appendix A of this Assessment Report summarizes EAO’s
conclusions and key proposed conditions for each VC. The remainder of this section
provides a summary of the key issues and concerns that were the focus of the EA.

4
It was determined through the EA process with input from the Working Group, LTFN
and the public, that there is a low likelihood that the Giscome Project would have
adverse economic impact and as a result there is no discussion in the Technical Report
on this EA pillar. It was also determined that there would be minimal effects to the
following VC’s: Wildlife and Wildlife Habitat; Archaeology; Recreation; Visual Aesthetics;
and, Acoustic Environment. As a result, the discussion below is focused on the three
significant issues raised during the EA:

potential effects of the Giscome Project related to Greenhouse Gas Emissions;

potential effects of the Giscome Project on Air Quality; and
potential effects of the Giscome Project on Aquatic Resources.

Greenhouse Gas Emissions

EAO assessed the impacts of Greenhouse Gas (GHG) emissions resulting from the
Giscome Project. The Giscome Project, if approved, would emit GHGs at all project
stages, however, the majority of emissions would occur during the operation of the kilns
which requires the combustion of fuels to heat the kilns and produce the marketable
lime products from crushed limestone. GHG emissions would also be released by the
combustion of fossil fuels in equipment and vehicles.

During the EA, public comments about GHG emissions specified concerns about the
choice of coal as the primary fuel for the kilns. The assessment of GHG emissions was
based on Graymont using only coal to heat the kilns; however, Graymont is examining
two other fuel options – biomass and natural gas – with their preferred option being
natural gas. The use of natural gas instead of coal as the fuel source for the kilns would
reduce the projects GHG emissions by about 14 percent (%). Please see table below
for a summary of fuel source and estimated GHG emissions:

Fuel Source GHG Emissions % Reduction in Emissions

(t CO2 e/year) (as compared to 100% coal)
100% Coal 716, 898 0%
100% Natural Gas 615,341 14%
100% Biomass 500,268 30%

Climate Action Secretariat (CAS) was an active participant in the EA and led the
development of information requirements and the discussion on the assessment of
GHGs. CAS reviewed and agreed with EAO’s conclusions on the effects of GHGs on
the environment. CAS is also actively involved in the Mine Review Committee permitting
process. Graymont would be required to pay BC’s Carbon Tax (currently $30/tonne) for
all fuels consumed and report GHG emissions to CAS pursuant to BC’s Greenhouse
Gas Emission Reporting Regulation thereby providing CAS an ongoing monitoring role
for the Giscome Project.

5
Graymont calculated GHG emissions in the Application using up-to-date Western
Climate Initiative methodology. All of the potential GHG emitting activities were
modelled and the total GHGs were calculated for the construction and operation
phases.

Given the nature of GHGs, which remain in the atmosphere for many years, the
Giscome Project would result in a residual effect on the environment. A cumulative
effects assessment of the residual effects of GHG emissions was not undertaken
because the comparison of GHG emissions to national and provincial targets inherently
considers the cumulative impacts of GHGs on the environment.

The GHG assessment conducted for the Application compares the Giscome Project’s
modelled estimated emissions to the 2012 GHG inventories for BC and Canada. In that
context, Giscome Project would result in an increase to the provincial GHG emissions of
1.19% and an increase to the federal GHG emissions of 0.105%.

Every tonne of GHG emissions has the same effect; the exact same contribution to
future impacts of climate change. There is no “safe limit”, “exposure” or “dispersion”
criteria that can be applied to a significance assessment for GHG. EAO has therefore
considered how the Giscome Project’s contribution to GHGs may impact BC’s ability to
meet its GHG reduction target after mitigation.

• The national GHG reduction rate to achieve 2030 target is expected to be 2% per
year.

• BC’s GHG reduction rate necessary to achieve legislated targets is 3% per year.

BC’s GHG target is comprehensive, meaning that it applies to the total GHG emissions
within the province, and each new tonne of GHG in BC adds to the burden to reduce
greenhouse gas emissions elsewhere in BC.

The Giscome Project will be subject to the following mitigation for GHG emissions:
1. Carbon tax will be paid for all fuels consumed (e.g. equipment, vehicles, and
operation of lime kilns). The tax is BC’s central tool to mitigate GHG emissions
from sources such as new industrial facilities. Currently the carbon tax is $30 a
tonne. The federal government recently announced the intent to have a Canada-
wide carbon tax escalating to $50 in 2022 and likely to increase in future years.

2. In order to ensure that Graymont is using the most fuel efficient technology and
to ensure that GHGs will not exceed what is contemplated in the Application, the
Certified Project Description includes the following requirements:
 The Giscome Project is defined as producing no more than the maximum
predicted GHG emissions in the Application (729,000 tonnes/year).
Amendment of the Certificate is required to exceed this amount.

6
  All kilns will use vertical kiln technology or will be replaced with Best
Available Technology that further reduces emissions, as determined by a
Qualified Professional;
 Kiln fuel source may be coal, wood, or natural gas or any combination of
these fuel sources; and
 Another fuel or energy source may be used if it reduces the concentration of
contaminants in the emissions and does not increase greenhouse gas
emissions from the kiln compared to estimates in the Application.

During operation of the Giscome Project emissions must be reported annually under the
Greenhouse Gas Emission Reporting Regulation of the Greenhouse Gas Industrial
Reporting and Control Act. This is not a limit on emissions, but it does mean the facility
emissions are covered by legislation and will be tracked and reported annually by
regulation.

British Columbia’s Climate Action Plan is a provincial policy with the goal of reducing
GHG emissions. The Plan outlines emission reduction targets and strategies, and
initiatives to achieve the targets. Specific policy measures have been applied to reduce
emissions in each economic sector. Provincial GHG mitigation measures include carbon
tax, emissions standards on vehicles, regulation of landfill gas emissions, a
low-carbon fuel standard, and encouraging green community development. BC has also
provided funding for capital investments, offset programs and new technologies that
contribute to innovations and incentives in reducing GHGs in industries including mining
and transportation. The BC Carbon Tax is expected to induce Graymont to select the
lowest emission and most economic fuel mix for the Giscome Project in the future.

Considering the analysis summarized above and discussed in Section 4 (Greenhouse

Gas Management) of the Technical Report and having regard to BC’s Climate Action
Plan, which includes the Carbon Tax that will apply at the start of the Project, and
requirements in the CPD, EAO is satisfied that the Giscome Project is unlikely to have
significant adverse effects related to GHG emissions.

Air Quality

The EA considered the Giscome Project’s impacts to air quality to determine the
significance of effects on human health. A change in air quality may result from
emissions associated with lime processing, material handling, and transportation in the
Regional Study Area (RSA). Several comments were received from the public about the
potential impacts of Giscome Project on air quality leading to effects on wildlife, human
health and farms in the area. Of particular concern were the potential impacts to school
children at the Giscome Elementary School located about one kilometre southwest and
down-wind of prevailing winds from the processing plant. The assessment of changes in
air quality to human health is discussed in more detail below. The EA also considered
possible impacts of air quality on vegetation, and associated indirect effects on wildlife,
however, it was determined that the impacts to these VC's would not be significant.

7
MoE – Air quality Section and Northern Health (NH) were the lead agencies providing
advice on impacts on air quality. MoE reviewed detailed air dispersion modelling
prepared for the EA and on several occasions requested clarification on the modelling
and additional information to assist with their review. NH required Graymont to prepare
a Human Health Risk Assessment (HHRA) during application review. The primary
objective of the HHRA was to “evaluate risks to general public human receptors as a
result of project sourced contamination.” NH reviewed the HHRA assessment and
requested clarification and additional information on several issues. Both MoE and NH
are participating in the Mine Review Committee that is reviewing Graymont’s
applications for permits.

The Air Dispersion model that was prepared by Graymont and reviewed by MoE
estimated PM2.5, PM10, total suspended particulates, nitrogen oxides, sulphur oxides,
and, mercury that would be generated by the Giscome Project. The modelling data
determined that there would be only one possible exceedance of the BC Ambient Air
Quality Objectives (BC AAQO). That exceedance was for PM10 which is in the
immediate vicinity of the quarry, resulting from dust generated during operation of the
quarry. Given the localized nature of the exceedance, and its occurrence on Crown land
with no residents nearby, it was determined that the effect would not be significant.

However, although PM10 was the only exceedance of the BC AAQO’s, both MoE and
NH were still concerned about the potential for impacts to human health especially in
relation to Giscome Elementary School. MoE commented that the school would
experience some level of air quality impact due to emissions from the processing plant.
NH commented that the long-term impacts to air quality should be considered even if
BC AAQO’s are not exceeded. In the end, both agencies agreed that the development
of a robust Air Quality Management Plan was imperative to mitigating impacts and
monitoring the air quality. They also agreed on the need to include adjacent
residents/community members and the school in the development and ongoing
implementation of the Air Quality Management Plan (Condition 15).

Considering the analysis summarized above and discussed in Section 7.1 (Air Quality)
of the Technical Report, and having regard to the proposed conditions and associated
mitigation measures, EAO is satisfied that the Giscome Project would not have
significant adverse residual effects on air quality.

Aquatic Resources

The EA considered the Giscome Project’s impacts on Aquatic Resources primarily from
the construction, operation and reclamation of the quarry. The assessment of the
Aquatic Resources VC included consideration of potential effects to fish and fish habitat
groundwater quantity and quality, surface water quantity and quality.

Construction and terrain alterations associated with the quarry may alter surface water
and groundwater runoff patterns, timing, and volume. Surface water quality of

8
surrounding watercourses could be affected by construction and operation activities,
including accidental spills or sediment runoff. Additionally there could be increases in
ammonia and nitrate from blasting activities and residue which could impact water
quality.

During the EA, changes in water quality to Bateman Creek and Eaglet Lake were
identified as key issues from environmental and community recreation perspectives.
Apart from fish and fish habitat, EAO also considered potential water quality effects to
birds and other wildlife inhabiting these water bodies. As identified in the Application,
fish populations in Bateman Creek and other tributary streams were considered as
indicators of environmental health. Eaglet Lake was identified as being important as a
community recreation resource, with some fish and fish habitat value. From a project
perspective it was determined that changes to terrain, water quality, and hydrology from
the development of the quarry specifically may affect fish habitat in Bateman Creek,
with lesser indirect effects to water quality in Eaglet Lake.

Overall, the predicted residual effects from the Giscome Project on aquatic resources
include changes to surface water quality, changes to surface water quantity, changes to
groundwater quantity, and direct alteration of fish habitat. Mitigation measures and
long-term surface and groundwater monitoring programs are proposed to address the
residual effects related to aquatic resources. These residual effects would occur in
Tributaries 7.2, Todd, Jules and Bateman Creeks; however no cumulative effects have
been predicted because no past, existing or reasonably foreseeable projects and
activities would interact with the Giscome Project within the same watersheds and
groundwater zone of influence.

MEM, MoE – Environmental Quality Section and FLNRO – Landbase Stewardship

Section were the lead agencies reviewing impacts on aquatic resources, and LTFN
through their consultant also had several comments and concerns. Graymont was
asked on several occasions to provide additional information and clarification regarding
their assessment of impacts on aquatic resources. Of particular concern were the
impacts to two tributaries, in and adjacent to the quarry area, that flow into Todd and
Bateman Creeks, and the potential impacts to water quality that may have downstream
effects on Eaglet Lake. In response to FNLRO’s concerns about the baseline studies,
Graymont developed and commenced new baseline monitoring programs during the
EA. The agencies were satisfied with the additional monitoring and modelling that was
provided and also acknowledged that additional permits and authorizations under the
Environmental Management Act and Mines Act will be required prior to the Giscome
Project proceeding. The agencies and LTFN also provided input into the proposed
conditions related to fish and fish habitat, and water management.

Considering the analysis summarized above and discussed in detail in Section 3

(Aquatic Resources) of the Technical Report, and having regard to the proposed
conditions and associated mitigation measures, EAO is satisfied that the Giscome
Project would not have significant adverse residual effects on Aquatic Resources.

9
Aboriginal Consultation
EAO examined potential impacts of the Giscome Project on asserted Aboriginal rights
and title (Aboriginal Interests). The Giscome Project lies within the asserted territory of
the LTFN.

Ethnohistoric, oral historic information and the Application indicate that the LTFN
historically used the area near the Giscome Project for many reasons, including, but not
limited to, travelling, hunting, fishing, trapping and camping at the time of European
contact. This information supports a strong prima facie claim of Aboriginal rights for
resource harvesting activities in the Giscome Project area. EAO is prepared to assume
that there is a moderate-to-strong prima facie claim to Aboriginal title to the Giscome
Project area. EAO has approached consultation with the LTFN at the deeper end of the
Haida consultation spectrum.

As part of the consultation process, EAO provided LTFN with capacity funding to
support their participation in the EA. LTFN actively contributed throughout the EA and
appointed a technical representative to EAO’s advisory Working Group. LTFN provided
comment on key EA documents, procedural and timing aspects, and met directly with
EAO to discuss issues and concerns.

EAO also assigned procedural aspects of consultation with LTFN to Graymont.

Throughout the EA, Graymont consulted with LTFN and shared information through
meetings, correspondence, presentations to Chief and Council, newsletters, a website,
site tours, and community open houses. Graymont and LTFN signed a consultation
protocol agreement in January, 2013, and a Mutual Benefits Agreement in September,
2014. With capacity funding from Graymont, LTFN managed and completed a
Traditional Use Study for the Giscome Project area and an archaeological impact
assessment. Funding was also provided, by Graymont, at LTFN’s request to assess the
potential for biomass as a fuel source for the project’s kilns. LTFN participated in
environmental field data collection for the project, and wildlife and wildlife habitat
assessments. EAO-required consultation reports and plans were reviewed and
approved by LTFN prior to being submitted to EAO. Under the Mutual Benefits
Agreement, LTFN supports the Giscome Project and its related approvals, and
Graymont agreed to provide employment, procurement and economic benefits to LTFN.
Section 7.4 of the Application provides a summary of Graymont-led consultation during
the pre-application phase.

During the PCP held for Application Review, Graymont held an additional open house
specifically for the Lheidli T’enneh community. The open house was held on January 9,
2016, at the Ramada Hotel in Prince George, and was attended by about 12 community
members. The open house included Giscome Project poster boards, and a question
and answer session with the Graymont team.

10
Some of the key concerns identified over the course of the EA by the LTFN include the
following:

Permanent loss of cultural locations or resources;

Wildlife monitoring;
Permanent alteration of project area habitat following decommissioning;
Reduction in availability of wildlife and fish species;
Diminished availability of traditionally used plants due to habitat loss;
Localized and regional pollution resulting in plants being unsuitable as medicine
and food;
Increased wildlife mortality due to road collisions;
Potential conflicts with road users;
Impacts of conveyor belt on wildlife;
Impacts to aquatic resources from increased road traffic/upgrade/construction;
Increased particulate loading in Eaglet Lake and surrounding watercourses;
Impacts to fish and fish habitat;
Impacts to plant growth from fugitive dust emissions; and
Impacts to human health from fugitive dust emissions.

Issues and concerns identified by LTFN in consultation with Graymont during the
Pre-Application Phase of the EA are described in Table 16-1of the Application.

EAO acknowledges there could be some potential impacts from the Giscome Project on
wildlife, vegetation and fish or aquatic resources and values of importance to LTFN.

During the EA, EAO has incorporated and responded to LTFN input on mitigations and
conditions related to surface water quality and quantity and fish and fish habitat. Based
on EAO’s understanding of LTFN historical and current use of the area, and the values
that are affected by Giscome Project, EAO does not expect that there would be impacts
to LTFN’s Aboriginal Interests to gather, hunt and fish. EAO is of the view that the
proposed EAC conditions, certified project description and agreements between
Graymont and LTFN would adequately address potential adverse effects to LTFN’s
Interests and concerns. Refer to Appendix A for a summary of the key EA issues
including those raised by the LTFN, EAO’s conclusions and the proposed certificate
conditions by VC.

EAO has ensured that LTFN has been meaningfully consulted and accommodated on
the potential effects of Giscome Project. EAO’s LTFN Consultation Report provides
further analysis related to these conclusions.

11
Public Consultation
Public consultation requirements are intended to provide multiple, meaningful
opportunities for the public to provide input. Graymont was required to prepare a Public
Consultation Plan early in the EA that laid out their consultation objectives and activities.
Through the course of the EA, Graymont submitted public consultation reports to EAO
describing the progress in implementing its Public Consultation Plan.

EAO hosted the following two PCPs and one open house during the EA:

A 30-day PCP was held by the EAO on the draft AIR from August 8 to September
8, 2014. The draft AIR was available for public review and comment at the Prince
George Public Library, the Regional District of Fraser-Fort George Office, the
Willow River General Store, and online on the EAO website. Five written
submissions were received during the PCP.

EAO held a 45-day PCP on the Application from December 1 to January 15,
2015. Hard copies of the Application were available at the Prince George Public
Library, the Regional District of Fraser-Fort George (RDFFG) Office, the Willow
River General Store, and digital copies were available online on the EAO
website. EAO held an Open House on December 10, 2015, and approximately
22 people attended.

The primary issues raised by the public during the open house and through the PCPs
were concerns regarding wildlife habitat, proximity of the process plant to Eaglet Lake,
air quality, traffic, potential impacts to water and fish habitat, potential impacts on
recreation and agriculture, and noise. EAO referred these comments to Graymont for
response. EAO considered Graymont’s responses when it evaluated the Application
review stage Public Consultation Report. EAO summarized issues affecting the public in
Section 1.3.3 of the Technical Report. EAO determined that the responses were
adequately addressed and that the issues raised informed the development of the
proposed conditions.

Refer to Appendix A for a summary of the key EA issues including those raised by the
Public, EAO’s conclusions and the proposed certificate conditions by VC.

Local Government Consultation

The RDFFG was represented on the Working Group and provided technical review
comments and participated in Working Group Meetings. The RDFFG provided input into
the development of the AIR including comments related to air quality and GHG impacts,
assessing potential impacts to recreation, ensuring adequate public consultation and
assessing impacts from the overland conveyor on wildlife. RDFFG did not provide
comments during the application review stage.

12
Graymont has also applied for amendments to the RDFFG Official Community Plan
(OCP) and Zoning bylaws for the processing plant, and RDFFG held a town hall
meeting to receive input from residents on the amendments.

Refer to Appendix A for a summary of the key EA issues, EAO’s conclusions and the
proposed certificate conditions by VC.

Additional Considerations
Ministers may consider other matters that they consider relevant to the public interest in
making their decision on whether to grant an EAC to Graymont.

Caribou

During the development of VCs for the Giscome Project, EAO determined, with input
from the WG and in particular FLNRO Ecosystems Branch, that Caribou did not merit
being included as a VC because suitable habitat did not exist in large enough quantities
in the local study area (LSA) to be sustainable for supporting caribou. The southern
mountain population relies heavily upon arboreal lichens found in the alpine and
Engelmann spruce-subalpine fir biogeoclimatic zones which do not occur within the
LSA.

In October 2016, the federal and BC governments announced a joint study to review the
regulations in place for the protection of Southern Mountain Caribou and their habitat.
The study will inform a Critical Habitat Protection Assessment conducted by the federal
government. Giscome Project is located within the boundaries of the Upper Fraser
Local Population Unit (LPU) of the Southern Mountain Caribou identified in the federal
recovery strategy.

With the announcement of the joint study, Graymont provided additional information on
caribou in relation to Giscome Project. Graymont’s assessment is that there is a low
likelihood that Giscome Project would impact caribou or their habitat for the following
reasons:

Giscome Project does not overlap with critical caribou habitat identified in the
federal recovery strategy.

The recovery strategy generally defines critical habitat for Southern Mountain
Caribou as all of the area of high elevation winter and/or summer range within
the boundary of each population unit and matrix range surrounding summer and
winter ranges. Giscome Project is not located in high elevation range. Matrix
range is considered lands that facilitate the movement of caribou between
seasonal ranges. Giscome Project is unlikely to be considered matrix range
because it is on the periphery of the Upper Fraser LPU and would be unlikely to
link areas identified as summer and winter habitats critical for recovery.

13
 Giscome Project is not close to existing ranges of caribou sub-populations.

A map included with the recovery strategy indicates that Giscome Project is
about 50 kms away from the nearest subpopulation range and is not in-between
existing subpopulation ranges.

Existing habitat in Giscome Project area is not high value caribou habitat.

The recovery strategy describes the types of valuable low elevation habitat as old
forests of cedar, hemlock and spruce, avalanche chutes, burns. In the southern
group, some subpopulations may move down into cedar/hemlock forests in valley
bottoms in the spring. The Giscome Project LSA contains limited habitat
characterized as old forest (~2%) and lacks contiguous tracts of high suitable
habitat. In addition to Giscome Project not being located near clearly identifiable
critical habitat, this would suggest that the LSA would have low priority for critical
habitat recovery actions.

The Ecosystems Biologist with FLNRO also reviewed this information and Graymont’s
assessment of the potential impacts of Giscome Project on caribou and agreed with
their conclusions. Based on the WG and EAO’s initial determination to exclude Caribou
as a VC from the EA, and on the October 14, 2016 additional information provided by
Graymont, EAO is satisfied that Giscome Project would not have adverse impacts on
Caribou and Caribou habitat.

Economic and Community Benefits

Giscome Project would result in increases to regional, provincial, and federal

government revenue streams. Graymont estimates that, during construction, revenue to
the province would be $1 to $2 million, and to the federal government $3 to $4 million.
During operations, the revenue would be roughly $400,000 per year to the local
government, $12 million per year to the provincial government, and $11.5 million per
year to the federal government.

Direct employment during construction is estimated by Graymont to be approximately

90 person-years, resulting in approximately $7.5 million in direct employment income in
the area. Graymont estimates that up to 65% of the construction workforce would be
hired locally, resulting in approximately $4.5 million in direct employment income for the
RDFFG area. During the operations phase, the workforce would initially consist of at
least 10-15 full-time employees and may rise to 20-25 full-time positions. Annual payroll
is expected to range from $1.2 million to roughly $2.0 million per year. Graymont
estimates that during operations, Giscome Project would create 1,000 person-years of
direct employment, resulting in over $80 million in direct employment income.

Community benefits include employment, community development support, and the use
of local supplies and services. Employees may choose to live in the area and those with
families would provide enrolment to the nearby Giscome Elementary School. In

14
addition, if natural gas is provided in the area to service the Project, it is hoped that the
gas line would run past the community of Willow River, enabling residents the option of
connecting to natural gas should they choose.

Potential Benefits to Affected Aboriginal Communities

Giscome Project’s benefits of economic development for the community and region are
also recognized by the LTFN community. Graymont has stated that they would
preferentially hire local businesses including Aboriginal persons and businesses which
meet employment and contracting requirements.

Under the Mutual Benefits Agreement that was signed between Graymont and the
LTFN, Graymont committed to providing employment, procurement and economic
benefits to LTFN.

The Province of BC intends to negotiate an Economic and Community Development

Agreement (ECDA) with the LTFN. An ECDA is an agreement between Government
and First Nations for sharing the direct mineral tax revenue from a new mine or a major
mine expansion.

EAO proposes several conditions which require Graymont to collaborate with LTFN on
the development and implementation of a number of management plans that relate to
Aboriginal Interests.

Conclusion
Based on:

Information contained in Graymont’s Application and the supplemental

information provided during Application Review;
Graymont’s and EAO’s efforts at consultation with LTFN, provincial and local
government agencies, and the public, and its commitment to ongoing
consultation;
Comments on the Giscome Project made by LTFN, provincial and local
government agencies, as members of EAO’s Working Group, and Graymont’s
and EAO’s responses to these comments;
Comments on the Giscome Project received during the PCPs, and Graymont’s
responses to these comments;
Issues raised by LTFN regarding potential impacts of the Giscome Project and
Graymont’s responses and best efforts to address these issues;
The design of the Giscome Project as specified in the proposed Schedule A
(CPD) of the EAC to be implemented by Graymont; and
Mitigation measures identified as proposed conditions in Schedule B (Table of
Conditions) of the EAC to be undertaken by Graymont.

15
EAO is satisfied that:

The EA has adequately identified and assessed the potential adverse

environmental, economic, social, heritage and health effects of Giscome Project,
having regard to the proposed conditions set out in Schedule B (Table of
Conditions) to the EAC;
Consultation with LTFN, provincial and local government agencies, and the
public, and the distribution of information about Giscome Project have been
adequately carried out by Graymont and that efforts to consult with LTFN would
continue on an ongoing basis;
Issues identified by LTFN, provincial and local government agencies, and the
public, which were within the scope of the EA, were adequately and reasonably
addressed by Graymont during the review of the Application;
Considering the proposed conditions for Giscome Project that would be legally-
required as part of any EAC as well as the application of any subsequent
permitting requirements, the potential adverse environmental, social, economic,
heritage or health effects of Giscome Project would be reduced to an acceptable
level and would not be significant;
The potential for adverse effects on LTFN’s Aboriginal Interests has been
avoided, minimized or otherwise accommodated to an acceptable level; and
The provincial Crown has fulfilled its obligations for consultation and
accommodation to potentially affected First Nations relating to the issuance of an
EAC for Giscome Project.

16
Appendix A: Summary of Giscome Project’s Key Issues and Effects on VCs

VCs
EAO’s Assessment and EAO’s Key Proposed
(Section of Technical
Conclusions Conditions
Report)

Environmental Effects

Wildlife and Wildlife Effects of the Giscome Project CPD:

Habitat – Section 2 on wildlife would mainly result
• Overland conveyer, rather
from vegetation clearing, and
construction and operation of the than roads. Includes wildlife
overland conveyor. passages for large animals.
Effects to wildlife may also be • Mature forest set-aside.
caused by sensory disturbance,
physical injury or mortality but Condition 12: Graymont must
would be reduced through update the Wildlife Management
avoidance and modification of Plan.
construction activities for Condition 13: Graymont must
nesting/ breeding periods hire a Qualified Environmental
With the mitigation measures Professional (QEP) to develop
incorporated in the CPD and the wildlife crossings.
proposed conditions, EAO is Condition 18: Graymont must
satisfied that the Giscome update the plan for Vegetation
Project would not have a Management in
significant adverse effect on Appendix 11.1-0.
wildlife and wildlife habitat.

Aquatic Resources – The Giscome Project would Condition 16: Graymont must
Section 3 result in changes to surface and update the plan for Water
groundwater quantity and Management in Appendix 5.3-6
quality, as well as loss of non- of the Application.
fish bearing and fish bearing
aquatic habitat.
Condition 14: Graymont must
With the mitigation measures develop a plan for the protection
incorporated in the proposed of Fish and Fish Habitat.
conditions, EAO is satisfied that
the Giscome Project would not
have a significant adverse effect
on aquatic resources.

0
 VCs
EAO’s Assessment and EAO’s Key Proposed
(Section of Technical
Conclusions Conditions
Report)

GHG Management – During operations, the Giscome CPD : The CPD defines the
Section 4 Project would result in the Project as producing no more
emissions of GHG’s. It’s than the maximum predicted
estimated that the Giscome GHG emissions in the
Project would result in an Application (729,000
increase to provincial GHG tonnes/year). Amendment of the
emissions of 1.19% and an Certificate is required to exceed
increase to the federal GHG this amount.
emissions of .105% based on The CPD also allows another
2012 GHG inventory. fuel or energy source to be used
(other than coal, biomass or
natural gas), but only if it
EAO is satisfied that the
reduces the concentration of
Giscome Project would not have
contaminants in the emissions
a significant adverse effects
and does not increase
related to GHG emissions.
greenhouse gas emissions from
the kiln compared to estimates in
the Application.
Monitoring and reporting are
required under provincial
regulations.
Graymont must pay the BC
Carbon Tax on all fuels.

Air Quality – Section 7.1 During construction and Condition 15: Graymont must
operations, the Giscome Project develop a plan for Air Quality
would impact air quality in the Management.
LSA. One possible exceedance
to the BC AAQOs was modelled
for PM10 that would occur within
the quarry site. In general, air
contaminants would increase as
a result of the Giscome Project,
however, the only exceedance to
BC AAQOs was PM10.
With mitigation measure
incorporated into the proposed
conditions EAO is satisfied that
the Giscome Project would not

1
 VCs
EAO’s Assessment and EAO’s Key Proposed
(Section of Technical
Conclusions Conditions
Report)

have a significant adverse effect

on air quality.

Social, Heritage and Health Effects

Acoustic Environment – The potential impacts on the CPD:

Section 7.2 acoustic environment would be Based on concerns from the
caused during operations public, Graymont relocated the
through operation of the kilns (24
proposed crushing and
hours a day/7 days a week) and
screening activities from the
quarrying (five days per week, plant site to the quarry to reduce
for 40 weeks per year). potential sources of noise near
With the mitigation measures Eaglet Lake and designed the
incorporated in the CPD and the proposed plant to reduce noise
proposed conditions, EAO is emissions.
satisfied that the Giscome Condition 21: Graymont must
Project would not have a implement acoustic mitigation
significant adverse effect on the measures for Noise
acoustic environment. Management.

2
 VCs
EAO’s Assessment and EAO’s Key Proposed
(Section of Technical
Conclusions Conditions
Report)

Archaeology – Section 6 The Giscome Project site Condition 17: Graymont must
contains one archaeological site construct a physical barrier
(GaRo-2). 14 areas of moderate around the archaeological site,
to high archaeological potential and must develop a Heritage
have also been identified within Management Plan.
the Giscome Project footprint.

Graymont would be required to

construct a physical barrier
around the archaeological site
and develop/update the Heritage
Management Plan.

With the mitigation measures

incorporated in the CPD and the
proposed conditions, EAO is
satisfied that the Giscome
Project would not have
significant adverse effects on
Archaeological resources.

Local climbers currently access Condition 11: Graymont would

Social Components –
Section 5 a climbing site just west of the work with the local climbing club
processing plant using the CN to determine safe access
(Recreation – Access to through Giscome property.
Farside Bluff) rail tracks and through
Graymont’s property. Graymont
has agreed to work with the local
outdoor club to determine a safe
route through Giscome property.

3
 VCs
EAO’s Assessment and EAO’s Key Proposed
(Section of Technical
Conclusions Conditions
Report)

Social Components – The Giscome Project is located Condition 23: Graymont would
Section 5 within trapping tenure consult with guide outfitters and
(TR0707T005). Graymont has trappers prior to construction and
(Guide Outfitter/Trapline would meet with individual guide
Tenure Holder) contacted the tenure holders and
would work with tenure holders outfitters, upon request, to
discuss impact and arrange
to mitigate/compensate for
suitable compensation for
changes in access and effects demonstrable affects to
on harvesting potential business.

With the mitigation measures

incorporated in the proposed
conditions, EAO is satisfied that
the Giscome Project would not
have significant adverse effects
on recreation.

Social Components – The lime plant is expected to Condition 20: Graymont must
Section 5 adversely affect visual aesthetics implement visual mitigation
due to the size and height of the measures including: screening
(Visual Aesthetics)
kilns stacks, lighting of the plant, berms, vegetation, neutral paint
and visible rock piles adjacent to colours, and downward oriented
the lime plant. There would be lights (to reduce light spill).
Graymont must also engage with
no visible emissions from the
the community each year to
stacks. receive feedback and track
resolution of issues.

With the mitigation measures

incorporated in the proposed
conditions, EAO is satisfied that
the Giscome Project would not
have a significant adverse effect
on the visual Aesthetics.