On July 3, The Nunavut Impact Review Board (NIRB) uploaded Information Requests (IRs) related to AREVA Resources Canada Inc’s Draft Environmental Impact Statement (DEIS) for the proposed Kiggavik uranium mine to the NIRB FTP site. IRs provide the opportunity for interested parties to submit initial questions to either AREVA or government regulators before beginning a full review of AREVA’s Draft Environmental Impact Statement.
Included in the upload were IRs from the Government of Nunavut (GN), the Kivalliq Inuit Association (KIA), the Baker Lake Hunters and Trappers Organization (BLHTO), the Beverly and Qamanirjuaq Caribou Management Board (BQCMB), Nunavummiut Makitagunarningit (Makita), the Lutsle K’e Dene First Nation (LDKFN), the Canadian Arctic Resources Committee (CARC), the Canadian Nuclear Safety Commission (CNSC), and various federal government departments. The IRs are available for download here.
The various IRs submitted make it clear that there are serious deficiencies in AREVA’s Draft Environmental Impact Statement. Taken together, the IRs from the various groups point to serious problems with the way AREVA studied many issues, including environmental contamination, caribou migrations, caribou health and impacts on Inuit society (both positive and negative). The IRs also highlight major problems with the way AREVA used Inuit Qaujimajatuqangit in the DEIS. Serious deficiencies in AREVAs monitoring plans are highlighted in some IRs, while others suggest that AREVA shirks its responsibility for mitigation in some instances, passing it off to various governing agencies.
This is the case, despite the fact that the DEIS was already sent back to AREVA for revisions by the NIRB in January of this year.
The most comprehensive criticism of AREVA’s document comes from the GN. The GN’s cover letter states “…there is consensus across the government departments reviewing the Draft EIS that the documentation has not met the GN’s expectations in term of level of detail regarding commitments to project design and mitigation nor analysis.” According to the GN, in some sections of the DEIS, the data, the methods and the analyses used by AREVA “are not sufficient to allow the GN to conduct a technical review of the Draft EIS at the moment.” The GN’s cover letter indicates that the information requests submitted are “priority items” and do not “reflect the full range of questions that remain unanswered”.
Brief Overview of Major Issues Raised in IRs
The CNSC’s IRs point to significant problems with the way AREVA analyzed the potential contamination of groundwater. The CNSC’s IR cites “huge uncertainties” in AREVA’s “groundwater and contaminant transport modeling” for reasons which include an insufficient number of tests and reliance on unsubstantiated assumptions. The CNSC also raised issues with the facts that AREVA’s discussion of possible environmental impacts from accidents was not comprehensive, and that AREVA’s discussion of background radiation levels was not appropriate for the Baker Lake area. Health Canada also voiced concerns about AREVA using background radiation levels that are inappropriate for the Baker Lake area.
The KIA’s IRs also point to major issues with the way AREVA analyzed potential contamination of the environment. The KIA criticized the DEIS for not considering environmental impacts related to dust blown from contaminated waste rock piles, and for not studying some ways AREVA’s milling methods might contaminate the groundwater.
The KIA also took issue with the way AREVA utilized Inuit Qaujimajatuqangit (IQ) in the DEIS. “IQ appears poorly incorporated into the DEIS. IQ quotes are selectively presented and how IQ was incorporated into the assessment process is unclear. References to incorporating IQ into the assessment are generally oblique and un-quantified.” Issues related to insufficient use of IQ were also raised by the BLHTO, Makita and the BQCMB.
The KIA and the BLHTO also raised issues with the quality of the IQ AREVA presented in the DEIS. Both organizations highlight substantial omissions of important Inuit land use activities in AREVA’s attempts to map out Inuit use of the Kiggavik area.
The BQCMB’s submission highlights serious problems with the way AREVA studied possible cumulative impacts on caribou. Cumulative impacts are impacts from one source, which might be small on their own, but combine with impacts from other sources to make a substantial impact. IRs from the BQCMB note that AREVA uses too small of an area to properly study cumulative impacts related to contamination, that the DEIS lacks a proper cumulative analysis of the impact of roads from multiple mines on caribou, and that the “inclusion of climate change in cumulative effects assessment is not adequate”.
Issues with AREVA’s cumulative analysis of impacts on caribou were also raised by the BLHTO, the CARC and the KIA. The BLHTO criticized the DEIS’s cumulative analyses regarding caribou for not properly considering exploration, for not considering other uranium mines that Kiggavik might make possible, and for not considering cumulative impacts on Inuit hunting of caribou. The KIA stated, “The cumulative effects assessment is difficult to follow, is lacking in almost all manner of quantitative analyses, has limited description of underlying assumptions, and is largely based on uncertain data.”
The BQCMB also raised serious concerns regarding the data about caribou AREVA is relying on. “Information presented on caribou distribution, movements and ranges is based on only one data source [a brief collaring program] with little analysis and without clear descriptions of its limitations or implications for assessment of effects.” The BQCMB’s submission also notes inconsistencies in the way AREVA collected data and that AREVA did not use Inuit Qaujimajatuqangit or other available sources to understand caribou migrations.
The fact that AREVA relies entirely on collar data to study caribou movements was also criticized by the KIA, the BLHTO and the LDKFN. The CARC criticized the over-reliance on collar data as well, stating “any conclusions based solely from collared-animal data are biased, incomplete, and inaccurate”.
The BLHTO’s IRs raised a series of issues with AREVA’s DEIS, which appear to be primarily based on a discussion paper the BLHTO released in May. Both the discussion paper and the IRs criticize the DEIS for ignoring localized impacts on caribou in favour of studying general, population level impacts. The BLHTO argues that this approach ignores the way hunters might be directly impacted by AREVA’s proposed mine, because these types of impacts are considered “not significant”.
Issues with the way AREVA determined what impacts were “significant” and what impacts were “not significant” were raised by the BLHTO, the KIA, the CARC and Makita. These groups all took issue with AREVA relying on “professional opinion” to decide what impacts were significant, without providing any discussion of what factors were considered in making these determinations.
Makita’s submission raised issues with AREVA’s socio-economic impact analysis. Makita criticized the DEIS for not discussing basic methodological issues, for ignoring many issues in their prediction of economic benefits for Nunavut, and for making various claims without providing proper justification. Makita’s IRs was the only submission that raised serious concerns with the way AREVA discusses impacts on community wellbeing. In particular, Makita highlighted the way AREVA seems to shirk responsibility for negative impacts on community wellbeing, placing the blame for impacts on individual Nunavummiut and placing the responsibility for mitigation on government agencies.
Other organizations also took issue with the way AREVA shirks responsibility for some aspects of mitigation. The KIA raised concerns that the DEIS does not accept responsibility to mitigate some impacts on caribou, and that “harvest management (regulation) is handed off to GN.”
Some organizations also criticized AREVA’s monitoring plans. According to the KIA, “The Wildlife Mitigation and Monitoring Plan is woefully lacking in a framework to adequately monitor potential impacts of the Project on caribou.”
Each intervener group raised many other important issues with AREVA’s DEIS, and the concerns outlined above merely represent “priority items”.