Nunavummiut Makitagunarningit (Makita) has completed its review of AREVA Resources
Canada Inc.’s Final Environmental Impact Statement (FEIS) for the proposed Kiggavik uranium mine. Makita appreciates the opportunity to provide comment on AREVA’s proposal and to act as an intervenor in the review of this proposal.
Makita requests that the Nunavut Impact Review Board (NIRB) not approve AREVA’s Kiggavik proposal at this time. Makita believes approval for Kiggavik should be withheld until:
AREVA further develops the Kiggavik proposal. The current proposal lacks concrete
timelines for production, which makes all analyses of impacts on the ecological and
socio-economic environment so uncertain that they are largely unreliable. Further, there
are serious deficiencies in the analyses of cumulative effects and the choice of
significance thresholds in the FEIS.
Nunavut regulators implement a policy/planning framework capable of controlling
induced development associated with the Kiggavik proposal. Kiggavik would be a “basin
opening” project, leading to increased exploration and mining for uranium in the
Kiggavik area. Nunavut requires a strategy to protect critical caribou habitat and places of
high cultural value before approving a basin opening project like Kiggavik
Makita has prepared technical comments on the following sections of AREVA’s FEIS, which support the above recommendation:
1) Analysis of Project Need and Purpose. AREVA does not provide a timeline for the construction and operation of the Kiggavik mine, and is seeking permission to construct Kiggavik at some undetermined (and possibly entirely hypothetical) point in the future after uranium markets have rebounded. Makita is aware that many industry analysts believe that it may be a considerable period of time before the price of uranium is high enough to make a relatively marginal project like Kiggavik economically viable. In the interim, the analyses contained in the FEIS will become outdated, as baseline conditions change. This makes all analyses and conclusions contained in the FEIS so uncertain that they are largely unreliable. Makita believes AREVA may simply be moving the Kiggavik project through the assessment process in order to sell it to another company. AREVA SA (the parent company of AREVA Resources Canada) has undergone significant financial turmoil in the recent past, and is in the process of liquidating assets in order to balance its books.
2) Cumulative effects assessment for caribou. AREVA has acknowledged that its goal for the Kiggavik project is to provide a base of operations for future uranium development in the area. Kiggavik is surrounded by other uranium mineralization and exploration projects. If AREVA is permitted to construct infrastructure (road and mills) in the area, it will significantly decrease the overhead costs for other companies to open mines in the area. As a result, if Kiggavik is approved, it will make the Baker Lake area much more attractive to the uranium industry, leading to increased exploration and mining for uranium in the area. This is called “induced development”. An analysis of cumulative effects should consider the basin opening potential of this project. A central component of an analysis of induced development should be consideration of whether or not Nunavut has a policy/planning framework capable of controlling induced development and ensuring it does not significantly affect caribou and the caribou hunting culture of Baker Lake Inuit. No such analysis is presented in AREVA’s FEIS. Makita believes that the current policy/planning framework in Nunavut is incapable of controlling the induced development Kiggavik would bring.
3) Significance threshold for impacts on wildlife. The significance thresholds selected by AREVA for wildlife define significant impacts as impacts that will threaten the long-term viability of the population. This is a very high-scale and abstract way to define significance. Makita believes that such an abstract conceptualization of significance is inappropriate for assessing impacts on wildlife species that Inuit rely upon for subsistence purposes. Under the current conceptualization, it would not be deemed significant if caribou avoided the Baker Lake area for the entirety of the project lifespan, so long as the herds were not entirely and permanently destroyed. A scenario of this sort would clearly constitute a significant impact for Inuit hunters and their families in Baker Lake. Due to the choice of inappropriate significance thresholds, AREVA’s analyses of all wildlife species harvested by Inuit are inadequate.
4) AREVA’s Approach to Sustainable Development. AREVA boasts that it has a strong commitment to sustainable development, including its “social responsibility that requires participation in community development and establishing relationships of trust.” In support of this claim, AREVA provides a lengthy description of its operations in Saskatchewan. Makita believes that AREVA’s portrayal of itself as a socially responsible enterprise is inaccurate, especially with regards to AREVA’s operations in many African countries. Makita has acquired several documentary films which demonstrate the negative impacts AREVA’s mines have had in Gabon and Niger. Makita requests that the NIRB provide the opportunity for Makita to present this evidence to the NIRB board, intervening parties, and residents of Baker Lake during the public hearing.
Makita’s full technical comments can be accessed here.