red mountain gold mine

RED MOUNTAIN GOLD MINE

PROJECT DESCRIPTION SEPTEMBER 2015

SUBMITTED TO:

BC Environmental Assessment Office

1st Floor, 836 Yates Street

PO Box 9426 Stn Prov Govt Victoria, BC V8W 9V1

Canadian Environmental Assessment Agency

Suite 410, 701 West Georgia Street, Vancouver, BC V7Y 1C6

PURSUANT TO:

British Columbia Environmental Assessment Act

and the Canadian Environmental Assessment Act 2012

SUBMITTED BY:

IDM Mining Ltd. 1500-409 Granville Street Vancouver, BC V6C 1T2

Red Mountain Gold Mine Project IDM Mining Ltd.

Project Description September 2015

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TABLE OF CONTENTS

ACRONYMS AND ABBREVIATIONS ........................................................................................ vi

1 PROPONENT INFORMATION ........................................................................................... 1

1.1 Introduction ............................................................................................................... 1

1.2 Regional Environmental Studies ............................................................................... 1

1.3 Proponent Background ............................................................................................. 4

2 PROJECT INFORMATION ................................................................................................. 5

2.1 Project History .......................................................................................................... 5

2.1.1 Historic Mineral Resource and Reserve Estimates ..................................... 6

2.1.2 Historical Production .................................................................................. 7

2.2 Project Overview ...................................................................................................... 7

2.2.1 Project Components ................................................................................... 7

2.2.2 Project Purpose and Rationale ................................................................... 9

2.2.3 Regulatory Framework for the Project .......................................................11

2.2.4 Project Capital Cost ...................................................................................11

2.2.5 Project Employment ..................................................................................12

2.3 Deposit Geology and Resource Characterization ....................................................13

2.4 Mine Development ...................................................................................................14

2.5 Mineral Processing ..................................................................................................15

2.6 Hazardous Waste Management ...............................................................................16

2.6.1 Mine Waste Rock ......................................................................................16

2.6.2 Tailings Management ................................................................................18

2.7 Water Management .................................................................................................18

2.7.1 Water Supply .............................................................................................18

2.7.2 Diversions .................................................................................................18

2.7.3 Contact Water ...........................................................................................19

2.7.4 Alternate Waste Water Treatment Facility .................................................19

2.8 Other Infrastructure ..................................................................................................19

2.8.1 Fuel Storage and Handling ........................................................................20

2.8.2 Explosives Storage and Handling Facility ..................................................20

2.8.3 Access Road from Highway 37A ...............................................................20

2.8.4 Power Line ................................................................................................20



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2.8.5 Site Offices ................................................................................................20

2.9 Mine Reclamation, Closure, and Monitoring.............................................................20

2.9.1 Underground Mine and Portal ...................................................................21

2.9.2 Access Road and Power Line Facilities .....................................................21

2.9.3 Mill and Ancillary Structures on-site ...........................................................21

2.9.4 Tailings Facilities .......................................................................................21

2.9.5 Environmental Monitoring ..........................................................................22

2.10 Alternatives ..............................................................................................................22

2.11 Proposed Development Schedule ............................................................................23

2.11.1 Environmental Assessment Schedule .......................................................23

2.11.2 Project Development Schedule .................................................................24

3 EXISTING ENVIRONMENT ...............................................................................................26

3.1 Physical Environment ..............................................................................................26

3.1.1 Climate ......................................................................................................26

3.1.2 Air Quality .................................................................................................27

3.1.3 Noise .........................................................................................................27

3.1.4 Hydrogeology ............................................................................................27

3.1.5 Surface Water Hydrology ..........................................................................28

3.1.6 Water Quality ............................................................................................29

3.1.7 Surficial Geology and Terrain ....................................................................31

3.2 Biological Environment ............................................................................................31

3.2.1 Terrestrial Ecology ....................................................................................31

3.2.2 Fish and Fish Habitat ................................................................................33

3.2.3 Wildlife, Avian Species, and Species at Risk .............................................34

3.3 Human Environment ................................................................................................38

3.3.1 Land and Resource Use ............................................................................40

3.3.2 Aboriginal Land Use ..................................................................................41

3.3.3 Viewscapes ...............................................................................................42

3.3.4 Archaeological and Heritage Resources ....................................................42

3.3.5 Aboriginal, Commercial, and Recreational Fishery and Fishing Areas .......43

3.4 Current Economics ..................................................................................................43

3.4.1 Demographics ...........................................................................................43



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3.4.2 Local Services ...........................................................................................44

4 POTENTIAL PROJECT EFFECTS ON THE ENVIRONMENT ...........................................45

4.1 Physical Environment ..............................................................................................45

4.1.1 Air Quality .................................................................................................45

4.1.2 Noise .........................................................................................................45

4.1.3 Hydrogeology ............................................................................................45

4.1.4 Surface Water Hydrology ..........................................................................46

4.1.5 Water Quality ............................................................................................46

4.1.6 Surficial Geology and Terrain ....................................................................46

4.2 Biological Environment ............................................................................................47

4.2.1 Wildlife and Vegetation ..............................................................................47

4.2.2 Fish and Fish Habitat ................................................................................47

4.2.3 Birds ..........................................................................................................48

4.3 Human Environment ................................................................................................48

4.3.1 Land and Resource Use ............................................................................48

4.3.2 Aboriginal Land Use ..................................................................................49

4.3.3 Viewscapes ...............................................................................................49

4.3.4 Economics ................................................................................................49

4.3.5 Socio-Community ......................................................................................52

4.3.6 Human Health ...........................................................................................52

4.3.7 Archaeological and Heritage Resources ....................................................53

4.3.8 Aboriginal, Commercial, and Recreational Fishery and Fishing Areas .......53

5 CONSULTATION ...............................................................................................................54

5.1 Aboriginal Groups ....................................................................................................54

5.1.1 Nisga’a Nation ...........................................................................................54

5.1.2 Engagement and Consultation Activities to Date .......................................56

5.1.3 Métis Nation of BC ....................................................................................62

5.1.4 Skii km Lax Ha ..........................................................................................62

5.1.5 Proposed Future Consultation and Engagement Activities with Nisga’a

Nation........................................................................................................62

5.1.6 Special Consultation Considerations Under the Nisga’a Final Agreement .64

5.1.7 Proposed Future Consultation and Engagement Activities with Other

Aboriginal Groups .....................................................................................64



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5.2 Public and Stakeholders ..........................................................................................65

5.3 Agencies ..................................................................................................................66

6 SUSTAINABILITY ..............................................................................................................67

7 ENVIRONMENTAL APPROVALS AND PERMITTING PROCESS ....................................68

7.1 Provincial Involvement, Approvals and Permitting....................................................68

7.2 Federal Involvement, Approvals, and Authorizations ...............................................69

7.2.1 Potential Trans-boundary Impacts .............................................................70

8 REFERENCES ..................................................................................................................74

APPENDICES

APPENDIX A: Photos of Red Mountain Gold Mine Project

LIST OF TABLES

Table 1: Summary of Past, Existing, and Reasonably-Foreseeable Projects that Occur in the

Northwest Region of BC ............................................................................................. 3

Table 2: Red Mountain Chronological Exploration Summary ...................................................... 5

Table 3: Summary of Resource Estimates ................................................................................. 6

Table 4: Approximate Footprint of On- and Off-Site Components – Red Mountain Gold Mine

Project ........................................................................................................................ 8

Table 5: Summary of Capital Costs ...........................................................................................12

Table 6: Number of Construction and Operating Jobs ...............................................................12

Table 7: Mineral Resource for the Red Mountain Gold Mine Project .........................................14

Table 8: Mine Production Schedule ..........................................................................................15

Table 9: Summary of Alternative Means of Carrying Out the Project .........................................22

Table 10: Anticipated Environmental Approvals and Project Development Schedule ................23

Table 11: Anticipated Operations, Decommissioning, and Closure Schedule ............................25

Table 12: Summary of Temperature Data for Bitter Creek Weather Stations ............................26

Table 13: Climatic Normals for Stewart BC for 1981 to 2010 .....................................................27

Table 14: Summary of Trace Elements with Concentrations in Excess of Freshwater Aquatic

Life Guidelines ..........................................................................................................30



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Table 15: Anticipated Wildlife Species of Conservation or Traditional Use Concern that are

Known to Occur or that May Occur in the Project Area .............................................35

Table 16: Nisga’a Population Reported in July 2014 .................................................................44

Table 17: Mine Labour Salaries ................................................................................................50

Table 18: Processing Labour Requirements & Costs ................................................................51

Table 19: G&A Labour Requirements & Costs ..........................................................................52

Table 20: NLG Comments and Concerns .................................................................................56

Table 21: Summary of Engagement and Consultation Activities to Date ...................................58

Table 22: List of Potential Stakeholders ....................................................................................65

Table 23: List of Anticipated Provincial Permits and Authorizations ...........................................68

Table 24: Proximity to Federal Lands ........................................................................................70

Table 25: List of Anticipated Federal Permits and Authorizations ..............................................70

LIST OF FIGURES

Figure 1: Regional Location for the Project ............................................................................... 4

Figure 2: Local Setting and Claim Boundary – Red Mountain Gold Mine Project ......................10

Figure 3: Location of Project Components – Red Mountain Gold Mine Project..........................17

Figure 4: Nisga'a Lands and Communities ................................................................................39

Figure 5: Regional Aboriginal Community Boundaries .............................................................55

Figure 6: Catchment Boundaries and Drainages ......................................................................72

Figure 7: Catchment Boundaries Drainages Regional View .....................................................73



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ACRONYMS AND ABBREVIATIONS

ABA Acid Base Accounting

AIA Archaeological Impact Assessment

AOA Archaeological Overview Assessment

AOC Areas of Concern

ARD Acid Rock Drainage

BC British Columbia

BCEAA BC Environmental Assessment Act

BC EAO BC Environmental Assessment Office

BMP Best Management Practice

CEA Cumulative Effects Assessment

CEAA Canadian Environmental Assessment Act

CEAA 2012 Canadian Environmental Assessment Act (promulgated in 2012)

COSEWIC Committee on the Status of Endangered Wildlife in Canada

D&F Drift and Fill

EA Environmental Assessment

EAC Environmental Assessment Certificate (pursuant to the BCEAA)

GDP Gross Domestic Product

GHG Greenhouse Gas

GIS Geographic Information Systems

HCA Heritage Conservation Act

HIA Health Impact Assessment

HHRA Human Health Risk Assessment

km Kilometre

kV Kilovolt

LU Landscape Unit

LSA Local Study Area

LH Longhole Stoping

m metre



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MEM Ministry of Energy and Mines

MFLNRO Ministry of Forests, Lands, and Natural Resource Operations

ML Metal Leaching

MMER Metal Mining Effluent Regulations

MNBC Métis Nation of BC

MoE Ministry of Environment

MOTI Ministry of Transportation and Infrastructure

MOU Memorandum of Understanding

MW Megawatts

NFA Nisga’a Final Agreement

NLG Nisga’a Lisims Government

NSR Net Smelter Return

PAG Potentially Acid-Generating

PEA Preliminary Economic Assessment

Project area The area in which construction and operation of the Project components occurs

RISC Resource Information Standards Committee

RSA Regional Study Area

SARA Species at Risk Act

SRK SRK Consulting (Canada) Inc.

TMF Tailings Management Facility

VC Valued Component

Red Mountain Underground Gold Project IDM Mining Ltd.


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1 PROPONENT INFORMATION

1.1 Introduction

IDM Mining Ltd. (IDM, the Proponent) proposes to develop and operate the Red Mountain Gold

Mine Project (the Project), an underground gold mine in the Bitter Creek Valley on a contiguous

group of mineral tenures known collectively as the Red Mountain property, located near

Stewart, in northwest British Columbia (Figure 1). The Project will extract high-grade gold and

silver ore to be processed on-site.

This Project Description describes how IDM proposes to construct, operate, and decommission

the Project. In addition, the Project Description describes the existing bio-physical and socio-

economic environment, and the principal interactions between the Project and the existing

environment.

The Project will likely require an Environmental Assessment Certificate (EAC) pursuant to the

British Columbia Environmental Assessment Act (BCEAA). A decision pursuant to the Canadian

Environmental Assessment Act, 2012 (CEAA 2012) will also be required.

IDM have begun to consult with regulators, the Nisga’a Nation (Nisga’a), as represented by the

Nisga’a Lisims Government (NLG), and the community of Stewart. This consultation, along with

consultation with other Aboriginal Groups, the Regional District of Kitimat-Stikine, the public,

and others as may be necessary, will continue throughout the pre-Application phase of the

review pursuant to BCEAA.

1.2 Regional Environmental Studies

A number of environmental studies have been undertaken in the region, primarily to the north

and west of Stewart, to support other proposed and active mining projects. The most recent of

these include the KSM Project and the Brucejack Project.

There is one environmental study in the regional area that IDM is aware of; the regional traffic

study with involvement from the BC Ministry of Transportation and Infrastructure (MOTI). The

purpose of the study was to develop a regional approach to managing industrial traffic-related

impacts along Highway 37, and potentially Highway 37A. IDM has not been asked to participate

in this study. IDM is unaware of any federal environmental studies underway in the region

pursuant to section 73 or 74 of the Canadian Environmental Assessment Act, 2012, and is

unaware of any other formal conservation plans for the region.



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Figure 1: Regional Location for the Project



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Numerous historic and more recent environmental studies have been undertaken to satisfy EA

information requirements for mining projects in the regional area. Table 1 below provides a

summary of past, existing, and reasonably-foreseeable future projects in the northwest region of

the province that have been, are, or may be subject to an EA review. Some aspects of these

projects may have a spatial and temporal linkage with the proposed Red Mountain Gold Mine

Project.

Table 1: Summary of Past, Existing, and Reasonably-Foreseeable Projects that Occur in the Northwest Region of BC

Past Projects Existing Projects Reasonably-Foreseeable

Projects

Eskay Creek Mine

Forrest Kerr Hydroelectric

Granduc Mine

Johnny Mountain Mine

Kitsault Mine

Northwest Transmission Line

Red Chris Mine

Silbak Premier Mine

Snip Mine

Sulphurets Mine

Tulsequah Chief Mine

Galore Creek Mine

Brucejack Mine

LNG Export Terminal

Long Lake Hydroelectric (under construction)

Kitsault Mine

KSM Mine

McLymont Creek Hydroelectric

Morrison Copper/Gold Project

Pacific Northwest LNG

Prince Rupert Gas

Transmission Project

Swamp Point Mine

Arctos Anthracite Mine

Bear River Gravel

Bronson Slope Mine

Granduc Mine

Kemess Underground Mine Project

Kinskuch Hydroelectric

Kutcho Mine

Schaft Creek Mine

Storie Moly Mine

Sustut Copper Project

Treaty Creek Hydroelectric

Turnagain Mine

Volcano Creek Hydroelectric



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1.3 Proponent Background

IDM Mining Ltd. (IDM) is a mineral exploration and development company listed on the Toronto

(TSX: IDM) Stock Exchange with a registered office in Vancouver, BC. IDM, formerly known as

Revolution Resources, underwent a name change and corporate restructuring in early 2014.

IDM entered into an Option Agreement to acquire the Red Mountain from Seabridge Gold in

2014. The gold and silver resources of the Red Mountain Gold Mine Project are IDM’s core

asset.

Project Name:

Red Mountain Gold Mine Project

Proponent: IDM Mining Ltd.

Rob McLeod M.Sc., P.Geo. President & CEO 1500 – 409 Granville Street Vancouver, BC V6C 1T2 Phone: 604-681-5672 Email: [email protected]

Principal Contacts: Rob McLeod President & CEO Phone: 604-617-0616 Email: [email protected]

Michael McPhie, M.Sc. Executive Chairman Phone: 604-558-6242 Email: [email protected]

Primary Consultant to Proponent: Falkirk Resource Consultants Ltd. Suite 900 – 999 West Hastings Street Vancouver, BC V6C 2W2 Phone: 604-558-6300 Email: [email protected]



Page 5 of 76

2 PROJECT INFORMATION

2.1 Project History

Placer mining commenced in Bitter Creek at the base of Red Mountain at the turn of the

century. Limited exploration was performed in the 1970’s for molybdenum mineralization.

Significant work on the property began in 1988 when Wotan Resources Inc. staked claims and

optioned the property to Bond Gold Canada Inc. (Bond) in 1989. Table 2 is a recent

chronological summary of exploration efforts on the Red Mountain property.

In 1988 and 1989, drilling led to the discovery of gold mineralization in the Marc and Brad

zones. Lac Minerals Ltd. (LAC) acquired Bond in 1991. Surface drilling on the Marc, AV, and

JW zones continued in 1991, 1992, 1993, and 1994. Underground exploration of the Marc zone

was conducted in 1993 and 1994. In 1995, Barrick Gold Corporation acquired LAC and

subsequently sold the property to Royal Oak Mines Ltd. (Royal Oak) in 1996. North American

Minerals Inc. (NAMC) purchased the property from the receivership sale of Royal Oak in 2000.

NAMC subsequently sold the property to Seabridge in 2002, which then optioned the property to

Banks Island Gold Ltd. (Banks). Banks terminated the option in 2013 and the property reverted

to Seabridge. Seabridge subsequently optioned the property to IDM in 2014.

Table 2: Red Mountain Chronological Exploration Summary

Year(s) Exploration Activity

1988-89 Staking of Red Mountain by Wotan Resources Inc.

1989 Red Mountain and Wotan properties optioned to Bond. Discovery of gold-silver mineralization by drilling in the Marc zone (3,623 m); airborne EM and magnetic survey.

1990 Exploration of Marc zone and adjacent area (11,615 m of drilling) by Bond.

1991 LAC acquired 100% of Bond. A 2,400 m drill program was completed on the Marc and AV Zones.

1992 Results of a 4,000 m drill program by LAC increased Red Mountain resources and indicated excellent potential for expansion.

1993 28,800 m of surface drilling defined the Marc, AV, and JW Zones and identification of the 141 Zone. An underground exploration adit allowed bulk sampling of the Marc zone. 8,600 m of underground drilling completed in the Marc zone.

1994 LAC completed a 350 m extension of the main decline, 30,000 m of underground drilling and 16,000 m of surface drilling.

1995 Red Mountain Project acquired by Barrick Gold following Barrick Gold’s take-over of LAC. No exploration work was completed by Barrick Gold.

1996 Royal Oak undertakes exploration to explore for additional reserves. Extended underground drift by 304 m and completed 26,966 m of surface and underground drilling.



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Year(s) Exploration Activity

2000 NAMC purchased the property and project assets from Price Waterhouse. Coopers, conducts detailed relogging of existing drill core and constructs a geological model for resource estimation purposes and exploration modeling.

2002-2012 Seabridge purchases property, completes two Preliminary Economic Assessment studies (PEA).

2012-2013 Banks options property, two surface drill holes completed, completes PEA study.

2014 IDM options property.

Source: IDM (2014)

Some mineral and placer sub-surface Crown grants exist in the Project area, however they have

all reverted back to the province.

2.1.1 Historic Mineral Resource and Reserve Estimates

Table 3 summarizes resource estimates that have been made by the various owners of the

property. Only the Banks 2013 estimate is considered to conform to NI 43-101 requirements of

the BC Securities Act Government of BC (2008).

Table 3: Summary of Resource Estimates

Date Company* Classification Tonnes In situ

grade Au g/t

In situ grade Ag g/t

In situ contained

Au oz.

In situ contained

Ag oz.

1992 LAC NA 2,500,000 12.8 38.1 1,028,800 3,062,300

1993 LAC NA 2,511,000 11.3 29.8 912,200 2,405,700

1994 LAC NA 2,500,000 10.0 - 803,700 -

1994 LAC NA 2,399,644 9.6 - 740,640 -

1994 LAC NA 2,401,855 10.5 - 810,820 -

1995 LAC NA 3,653,854 7.7 - 904,500 -

1995 LAC NA 1,938,084 9.7 - 604,400 -

1996 ROM NA 3,143,880 5.69 22.87 575,273 2,094,770

1997 ROM NA 2,736,000 5.16 20.72 453,573 1,822,357

1998 ROM NA 2,457,840 6.31 18.06 498,507 1,427,789

2013 Banks M&I 1,612,000 8.4 28.3 432,000 1,440,000

2013 Banks Inferred 807,000 5.4 10.2 140,000 260,000



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2.1.2 Historical Production

No historical production has taken place on the property. 2,005 explorations of underground

workings including a 700 meter decline currently extends from the existing portal at 1,860 m

elevation over the entire strike length of the known resource, well situated at the top and parallel

to the mineralized zones. Three cross-cuts were driven in 1993 to complete a bulk sample of the

Marc Zone. The existing decline is about 5 m wide by 4 m high and was driven at a grade of -6

to-17%. The decline is suitable for production equipment.

2.2 Project Overview

The preliminary Project design is based on the following:

Production from underground mining and surface milling will be at a rate of 1,000 tonnes per

day (tpd);

The mine would operate for approximately nine months per year;

The estimated life-of-mine operational period is five years, based on environmental

conditions and known resources with the possibility of an additional two years if a sufficient

future metal price increase raises the ore cut-off grade. Local surficial exploration has not

identified additional resources at this time; and

Mine site decommissioning will commence in the year subsequent to the cessation of

operations.

Recent glacial recession and newly-exposed areas proximal to the deposit have enhanced

exploration potential. Exploration activities occurred during the 2014 field season and will

continue through 2015; however, there are no plans in the foreseeable future to expand the

scope of the Project beyond what is described in this Project Description, and it is understood

that any future changes will be subject to regulatory approvals.

2.2.1 Project Components

Off-Site Components consist of the following:

13 km of existing access road interconnecting with Highway 37A and following the Bitter

Creek Valley;

7 km of new and/or upgraded seasonal access roads between Hartley Gulch and Otter

Creek, connecting the existing access in the Bitter Creek Valley to the mine site and portals;

A 34 kV power line aligned to the first 13 of the 20 km seasonal access road, and continuing

to the mine site via a new alignment not necessarily adjacent to the remaining 7 km of road.

The new alignment will be determined based on the safest most direct route to the mine site.

The power line will connect to existing BC Hydro infrastructure in the Bear Creek Valley;

Existing core yard in Stewart; and

Off-site accommodation for workers (no accommodation will be constructed on-site).



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On-Site Components consist of the following:

Underground Mine Development:

o One new portal and an existing portal;

o Extension of stopes and underground workings;

Mineral Processing Facilities, including:

o A new 1000 tpd mill;

Waste Management Facilities:

o Temporary waste rock storage area;

o New tailings management facility including;

o Tailings dam;

o Tailings pond;

o Tailings drainage control structures; and

o Tailings operations.

Water Management Facilities

o Water Diversions

o Water treatment facility (if required);

New surface warehouse and mine dry facilities;

Concrete batch plant (construction-phase only);

New fuel and explosives storage facilities;

New power line and step down facilities on-site;

New site offices and assay lab;

Upgraded and new on-site access;

New sewage and septic works; and

New surface maintenance shop.

All on- and off-site components will be temporary: they will be reclaimed and removed

subsequent to the cessation of production. Note that the concrete batch plan will be

decommissioned and reclaimed following the completion of construction. The approximate areal

footprint of the on- and off-site components are summarized below.

Table 4: Approximate Footprint of On- and Off-Site Components – Red Mountain Gold Mine Project

Components Approximate Footprint

(ha)

Road 77.72

Power Line 127.14

Mineral Processing Facilities 1.78

Administrative Facilities 0.61

Tailings Management Facility 13.69

Total 220.94



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2.2.2 Project Purpose and Rationale

The purpose of the Project is to develop the Red Mountain deposit as an economically and

environmentally sustainable enterprise that provides meaningful benefits to Nisga’a and other

stakeholders including local communities and local, provincial, and federal governments.

IDM is committed to developing the Project in a manner that is consistent with the long-term

interests of future generations and the environment of the region.

This document outlines the conceptual plans for development of the Project to enable the BC

EAO to determine whether a provincial assessment pursuant to the BCEAA is required. Should

the BC EAO decide to issue a Section 10 Order for the Project, IDM expects to submit an

Application for an EAC.

This document is also intended to allow the Canadian Environmental Assessment Agency to

determine the requirements for review of the Project pursuant to CEAA 2012.

2.2.2.1 Property Location and Description

The Project is situated in northwest British Columbia, approximately 18 km east-northeast of

Stewart as shown in Figure 2. The Project is located at 55º57’53”N Latitude and 129º41’28”W

Longitude (UTM coordinates: 452,450 E, 6,250,325 N, Zone 9, NAD 83), adjacent to the

Cambria Ice Field and the Bromley Glacier at elevations ranging between 1,500 and 2,000 m.

The Project area is characterized by rugged, steep terrain with weather conditions typical of the

northern coastal mountains including significant snow accumulation, typically of more than 2 m,

in the winter. Access to the site is presently by helicopter from Stewart with a flight time of 10 to

15 minutes. An existing access road extends for approximately 13 km along Bitter Creek Valley

but stops approximately 7 km from the proposed mine site.

The Project consists of 40 contiguous mineral claims, totalling 14,250 ha. No significant risks

are identified which would affect title or the right or ability to perform work on the property.

The Project falls within the Nass Wildlife Area as set out in Nisga’a Final Agreement (NFA).

Pursuant to the NFA, Nisga’a has Treaty rights to the management and harvesting of fish and

wildlife within the Nass Wildlife Area. The Project is also within the asserted traditional territories

of Skii km Lax Ha and the Métis Nation of BC (MNBC).



Page 10 of 76

Figure 2: Local Setting and Claim Boundary – Red Mountain Gold Mine Project



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2.2.2.2 Property Ownership

On April 15, 2014, IDM entered into an Option Agreement for the Project with Seabridge.

Tenure title is currently under Seabridge and upon satisfaction of the option terms, title will be

transferred to IDM. Seabridge owns 100% of the property claims subject to two royalties. Franco

Nevada Corporation holds a 1% Net Smelter Return (NSR) royalty and a 2.5% NSR royalty is

payable to Wotan Resources Corp.

As a condition of the Mineral and Coal Exploration Activities & Reclamation Permit No. MX-1-

422 (MEM, 2002), Seabridge is required to complete annual monitoring activities to document

conditions at the Red Mountain site, including:

Collection and analysis of seep and crib drainage samples;

Monitoring of dump weathering; and,

Documenting general site conditions.

Through the Option Agreement, responsibility for the annual monitoring work is transferred to

IDM.

2.2.3 Regulatory Framework for the Project

The Project will have a production capacity of approximately 275,000 tonnes/year. This

production capacity will exceed the criteria of 75,000 tonnes/year of mineral ore described in

section 3(1) of the Reviewable Projects Regulation pursuant to BCEAA. The Project is therefore

expected to require an EAC pursuant to BCEAA as well as an operating permit under the BC

Mines Act.

The Project is exceeds the minimum daily ore production threshold of 600 t/day identified in

section 16 of the Schedule of the Regulations Designating Physical Activities under CEAA 2012.

The Project is therefore expected to require a decision pursuant to CEAA 2012.

The anticipated regulatory approvals, authorizations, and permits are described in section 7.

In addition, consideration will be given to the requirements of NFA Chapter 10, section 8, as

discussed in section 5.1.6.

2.2.4 Project Capital Cost

The capital cost (CAPEX) estimate includes all costs required to develop, sustain, and close the

operation for a planned 5-year operating life. The construction schedule is based on an

approximate 24-month construction period.

The high-level CAPEX estimate is shown in Table 5. The sustaining capital is carried over

operating Years 1 through 5, and decommissioning and closure costs will begin to be expended

in Year 6.



Page 12 of 76

Table 5: Summary of Capital Costs

Capital Cost Pre-Production

(C$M) Sustaining/

Closure (C$M) Total (C$M)

Crushing & Milling 23.8 0.0 23.8

Tailings Pond 3.7 11.6 15.3

Power 10.2 0.0 10.2

Mine Development 10.5 4.8 15.3

Infrastructure 2.5 0.6 3.1

Surface Equipment 1.1 0.0 1.1

Site Access Roads 5.9 0.0 5.9

Owner, Indirects, EPCM 8.6 0.0 8.6

Closure (Net of Salvage Value) 0.0 1.4 1.4

Subtotal Pre-Contingency 66.3 18.4 84.7

Contingency 9.8 2.8 12.3

Total Capital Incl. Contingency 76.1 21.2 97.0

Source: IDM (2014)

2.2.5 Project Employment

The Project is expected to generate the employment shown in Table 6.

In the first year of construction, the primary focus will be on access and on-site infrastructure. In

Year 2, the remaining on-site facilities will be constructed. Wherever feasible, priority will be

given to employment for people in the local and regional communities.

Table 6: Number of Construction and Operating Jobs

Red Mountain Gold Mine Project Projected Person-Years

Construction Mine Operation

Year 1 Year 2 Year 1 Year 2 Year 3 Year 4 Year 5 Year 6

Construction Persons 20 120

Construction Person-Years* 15 90

Number of Employees 0 39 98 98 94 94 94 8

Employee Person-Years* 0 29 74 74 71 71 71 6

Total Construction Person-Years 105

Total Employee Person-Years 396

*Number of persons working seasonally 9 months/year. Source: IDM (2014)



Page 13 of 76

2.3 Deposit Geology and Resource Characterization

Red Mountain is located near the western margin of the Intermontane Belt. There are three

primary stratigraphic elements in Stikinia and all are present in the Stewart area: Middle and

Upper Triassic clastic rocks of the Stuhini Group, Lower and Middle Jurassic volcanic and

clastic rocks of the Hazelton Group, and Upper Jurassic sedimentary rocks of the Bowser Lake

Group. Many primary textures are preserved in rocks from all of these groups, and mineralogy

suggests that that the regional metamorphic grade is probably lower greenschist facies.

Mineralized zones consist of crudely tabular, northwesterly trending and moderately to steeply

southwesterly dipping gold and silver bearing iron sulphide stockworks. Pyrite is the

predominant sulphide, however, locally pyrrhotite is important. The stockworks zones are

developed primarily within porphyry and to a lesser extent in rafts of sedimentary and

volcaniclastic rocks.

The stockwork zones consist of pyrite microveins, coarse-grained pyrite veins, irregular coarse-

grained pyrite masses, and breccia matrix pyrite hosted in a pale, strongly sericite altered

porphyry. Vein widths vary from 0.1 cm to approximately 80 cm but widths of 1 to 3 cm are most

common. The veins are variably spaced and average 2 to 10 per metre. The veins are very

often heavily fractured or brecciated with infillings of fibrous quartz and calcite. Orientations of

veins in the stockworks are variable, however, sets with northwesterly trends and moderate to

steep north-easterly and south-westerly dips have been identified in underground workings.

The pyrite veins typically carry gold grades ranging from ~3 g/t to greater than 100 g/t. Gold

occurs in grains of native gold, electrum, petzite and a variety of gold tellurides and sulphosalts.

The stockwork zones are surrounded by more widespread zone of disseminated pyrite and

pyrrhotite alteration.

Mineable tonnages were derived from a resource model. A resource model is the accumulation

of all exploration drilling information in a computer database used to generate a three-

dimensional geological representation of the ore body or “resource”. Measured, indicated, and

inferred resources were used to establish the mineable tonnes as presented in Table 7.



Page 14 of 76

Table 7: Mineral Resource for the Red Mountain Gold Mine Project

Zone Tonnage

(tonnes)

In situ Gold Grade

(g/t)

In situ Silver Grade

(g/t)

Contained Gold

(Troy ounces)

Contained Silver

(Troy ounces)

Marc Zone

Measured 651,600 9.26 40.06 194,000 839,215

Indicated 10,800 9.71 30.33 3,400 10,477

Inferred 0 0.00 0.00 0 0

AV Zone

Measured 508,200 7.14 20.88 116,700 341,202

Indicated 283,800 7.32 21.03 66,800 191,935

Inferred 1,800 10.96 39.50 600 2,308

JW Zone

Measured

Indicated

Inferred 331,100 7.67 12.57 81,600 133,900

Total Measured & Indicated

1,454,300 8.15 29.57 380,900 1,382,800

Total Inferred 332,900 7.69 12.72 82,300 136,200

Source: JDS (2014)

Note: Mineral resources are taken from the 2014 PEA Mineral Resource Statement for the Red Mountain Gold Mine Project at a 3 g/t Cut-off Grade; 3 g/t Au is calculated as the cut-off grade for underground long-hole stoping

2.4 Mine Development

Two mining methods were selected based on deposit body geometry and grade of the mineralized zones:

Longhole stoping (LH) for mining blocks steeper than 55 degrees, which represents about 82% of mineable tonnage. This is the preferred mining method from productivity and operating cost perspective.

Drift and Fill (D&F) for mining blocks with dips of less than 55 degrees, which represents about 18% of mineable tonnage.

Cemented and uncemented rock fill will be used as backfill to maximize mining recovery.

The initial mine design was based on basic assumptions to generate lower limits for cut-off

grades (COG) for the two planned mining methods. A value of 3 g/t Au was determined as the

COG for longhole stoping and 5 g/t Au for D&F run-of-mine mining. These COG’s were used to

design initial mining shapes.



Page 15 of 76

Mining recovery and dilution factors were applied to each mining shape based on the mining

method used. The estimated mineable tonnes for the Project are summarized in Table 8.

The mine plan focusses on accessing and mining higher grade material early in the mine life. As

such, the plan commences with mining of Marc, followed by AV, and then JW. The mine

production rate is targeted at 1,000 tpd. Production in the last year of mining was slightly

increased to 1,085 tpd.

Table 8: Mine Production Schedule

Zone Unit Yr 1 Yr 2 Yr 3 Yr 4 Yr 5 Total

Marc

Tonnage Tonnes 270,137 189,851 28,827 - 26,995 515,809

Gold Grade Au g/t 10.35 6.88 7.82 - 4.47 8.62

Silver Grade Ag g/t 42.94 27.48 27.32 - 33.38 35.88

AV

Tonnage Tonnes - 82,516 242,424 201,485 186,580 713,006

Gold Grade Au g/t - 7.16 6.38 5.80 5.54 6.09

Silver Grade Ag g/t - 21.37 16.41 19.96 19.62 18.83

JW

Tonnage Tonnes - - - 69,990 79,455 149,445

Gold Grade Au g/t - - - 7.48 8.57 8.06

Silver Grade Ag g/t - - - 14.10 9.61 11.71

Total Mine

Tonnage Tonnes 270,137 272,367 271,251 271,475 293,030 1,378,260

Gold Grade Au g/t 10.35 6.97 6.53 6.24 6.26 7.25

Silver Grade Ag g/t 42.94 25.63 17.57 18.45 18.18 24.44

Source: JDS (2014)

Underground access will be through two portals: the existing exploration decline at 1,860 m EL

and a new portal at 1,650 m EL. Access ramps will be driven at maximum grade of 15% at a 4.5

by 4.5 m profile to accommodate 30 tonne haul trucks. Level spacing is variable, up to a

maximum of 30 metres. Mineralized zone development will be on a 4.0 x 4.0 m profile.

2.5 Mineral Processing

Gold and silver will be extracted by cyanidation from run-of-mine mineralized material delivered

to the mill complex. The run-of-mine material will be stage crushed by a jaw and cone crusher

and stored in a fine mill feed material bin. At a nominal rate of 1,000 TPD, the fine mineralized

material bin will feed a conventional rod and ball mill grinding circuit followed by thickening prior

to leaching. Target grind size will be 95 % passing 38 microns (“P95 38µm”).

Gold and silver extraction will be accomplished in leach tanks with carbon in pulp adsorption,

carbon elution, regeneration, electrowinning, and refining. Tailings will be treated with SO2 and

air to destroy cyanide prior to discharge to the TMF. Initial geochemistry of the ore indicates that



Page 16 of 76

this processing is feasible with respect to meeting applicable effluent quality discharge

requirements, specifically Metal Mining Effluent Regulations (MMER’s). Further geochemical

testing and analysis will be completed to establish the characteristics of the resulting process

water.

Mineral processing will occur at a mill located on site. Processed doré bars will be transported

from site via truck to Stewart where they will then be transported to a domestic or international

refinery.

Total number of truck trips per day primarily to and from Stewart to the project site is estimated

at approximately 50 – 60. These will made up of the transportation of employees, equipment,

supplies and doré bars.

2.6 Hazardous Waste Management

Gold and silver extraction will be accomplished in leach tanks with carbon in pulp adsorption,

carbon elution, regeneration, electrowinning and refining. Tailings will be treated with SO2 and

air to destroy cyanide prior to discharge to the tailing management facility. Initial geochemistry

of the ore indicates that this processing is feasible with respect to meeting applicable water

quality discharge requirements, specifically MMER’s. Further geochemical testing and analysis

will be completed to establish the characteristics of the resulting process water.

The 2014 estimates are for 521,000 tonnes of development waste rock and 1,378,260 tonnes of

tailings from mill processing of mineralised material. There will be no concentrate storage on the

site as the end product is ore gold.

2.6.1 Mine Waste Rock

Development waste rock will be temporarily stored on the ground surface outside the

underground workings in the general area shown in Figure 3 and reclaimed for backfill during

mining operations. No surface waste rock storage upon mine closure is foreseen. The areas

used for temporary waste rock storage during operations will be rehabilitated during operations

as appropriate or at the latest upon mine closure.

Static acid base accounting (ABA) tests have indicated that the waste rock is potentially acid-

generating (PAG). On-going monitoring of waste rock from the 1994 to 1997 exploration

programs indicates there is a long lag time to the onset of acidic conditions if this material is in

place for more than 16 years. Therefore, ARD is not expected to occur over the life of the mine.

At closure, a hydrostatic bulkhead will be installed at the lower portal to prevent air circulation

and allow the workings to flood. A hydrogeological evaluation is being initiated to estimate post-

closure water levels in the mine.



Page 17 of 76

Figure 3: Location of Project Components – Red Mountain Gold Mine Project



Page 18 of 76

2.6.2 Tailings Management

Tailings management at the Project will employ the most advanced engineering and design

characteristics available. The tailings are potentially acid- generating (PAG), and will require

appropriate management plans to prevent or mitigate metal leaching (ML) and acid rock

drainage (ARD).

Tailings will be stored in a TMF located adjacent to the processing facility. The final design of

the TMF is still under consideration and study. The current design of the TMF, as included in the

July 2014 PEA, is to have a tailings pond formed by a lined engineered earth dam constructed

from local borrow material which will be designed to maintain saturated conditions throughout

the tailings mass. An alternative, which is currently under investigation, is the use of cemented

tailings surface deposition, where cement is blended into the tails prior to deposition within the

TMF. The intent of adding cement is to create a solid tailings mass at surface. Testing is

currently underway to explore the feasibility of cemented tails as an option, and a final

determination on the TMF design will be made when cemented and other tailings deposition

options have been fully examined.

The tailings pond will receive tailings and wastewater from the mill after cyanide removal.

Surface runoff that would normally drain to the TMF location will be diverted around and or

beneath the TMF and will be an integral part of the TMF design.

2.7 Water Management

The tailings pond dam elevation will be constructed to allow for sufficient freeboard to allow for

year-round containment of water during operations, including peak snow melt and rain events.

2.7.1 Water Supply

Water will be required for human consumption, on-site activities for maintaining facilities, and for

the processing in the mill. This water will be brought in from Stewart.

Mill processing water will be reclaimed from the TMF through a barge-mounted reclaim system

in the tailings pond. It is estimated that approximately 20,833 litres/hour (5,504 US gallons/hour)

will be required for processing make-up water.

The make-up water is to be derived from the underground mine discharge. When insufficient

make-up water is available from the underground mine, water will be drawn from the Goldslide

Creek basin underflow below the tailings dam.

2.7.2 Diversions

Diversion channels will be constructed to divert water (non-contact) from areas up-slope of the

plant site, temporary stockpiles and tailings facility, and upstream in Goldslide Creek. The

diversion channels will be sized to accommodate peak flows and the flows will be returned to

Goldslide Creek at the downstream side of the tailings facility. The point at which the diverted



Page 19 of 76

flows return to Goldslide Creek will be designed to prevent erosion and also allow extraction of

water, should additional make-up water be required for the mill.

2.7.3 Contact Water

Contact water includes water from the underground mine, process water, and water that comes

into contact with waste rock, the mill area, or the tailings impoundment.

Water from the underground mine is expected to drain by gravity to the secondary portal at

elevation 1,650 m. This water will be intercepted for use in the processing of the ore at the mill.

Water quality monitoring completed during the 1996 and 1997 exploration programs, as well as

more recent monitoring at the surface of the mine pool in the existing decline, indicate that the

underground water quality meets the requirements for discharge to the receiving environment.

Underground water quality will continue to be monitored during operations and, depending on

the results, excess water from the mine will be either discharged directly to the environment or

directed to the tailings pond for process makeup water.

Process water, runoff from the mill area, seepage from the temporary waste rock stockpiles, and

runoff from the tailings beaches will be directed to the TMF. It is estimated that the TMF water

balance will be consumed by the mill operations with a minor net deficiency requiring surface

water collection to be used intermittently for operations makeup water. Further work is required

to determine a final water balance and whether intermittent discharge to the receiving

environment would be required.

The quality of water that will be discharged from the tailings pond is expected to meet Canadian

MMER guidelines. If further testwork and monitoring indicates this is not the case, then the

water will be treated prior to discharge.

2.7.4 Alternate Waste Water Treatment Facility

Waste water treatment is not expected to be required for this Project. However, in the event that

further engineering studies indicate that a treatment facility is required and should be assessed

for purposes of decisions pursuant to BCEAA and CEAA 2012, a detailed design will be

provided. Subject to the feasibility studies, a detailed waste water treatment concept will be

provided and will form the basis for the environmental assessment of the facility as an alternate

to managing ARD and other parameters that regulators may require to be treated.

2.8 Other Infrastructure

IDM is committed to operating the mine in a sustainable manner and every reasonable effort will

be made to minimize any short- and long-term environmental impacts. IDM will establish an

environmental management policy and process for the Project to ensure that the above

objectives and requirements of regulators, NLG, and stakeholders are met.



Page 20 of 76

2.8.1 Fuel Storage and Handling

A designated fuel storage and handling area with spill and seepage control and prevention will

be provided on-site. This are will be combined with a place for emergency on-site vehicle and

equipment maintenance; routine and scheduled vehicle maintenance will be carried out in

Stewart.

2.8.2 Explosives Storage and Handling Facility

A designated area will be established for storage and handling of explosives required for

construction, mining operations, and closure activities. The storage and handling of explosives

will comply with federal Explosives Regulations, 2013, SOR/2013-211 (Government of Canada,

2013).

2.8.3 Access Road from Highway 37A

To minimize erosion and damage to the access road, a drainage design and road drainage

management plan will be prepared to meet environmental requirements and minimize the

introduction of contaminants to Goldslide Creek and Bitter Creek.

In addition, IDM will work with regulators to identify a management plan for the existing road

from Highway 37A to the Project access road.

These plans will address the three-month closure period each year of construction and mine

operation and critical natural hazard periods along the roads.

2.8.4 Power Line

A 34 kV electrical power line will be constructed parallel to the first 13 km of seasonal access

road and continuing to the mine site via a new alignment not necessarily adjacent to the

remaining 7 km of road. Step-down facilities will be constructed at the mine site. The power line

will connect to existing BC Hydro infrastructure in the Bear Creek Valley.

2.8.5 Site Offices

New site offices will be placed at the mine site. Offices will consist of several temporary Atco

type trailers and other temporary structures.

2.9 Mine Reclamation, Closure, and Monitoring

The mine closure concept is to have the site returned to a safe condition, environmentally sound

and rehabilitated condition to minimize the intrusion of the Project on the landscape. Further

testwork during additional more detailed engineering studies will confirm the final closure plan

and concepts.



Page 21 of 76

2.9.1 Underground Mine and Portal

All underground development rock would be placed as backfill in the mining process.

Following closure, the underground mine will be allowed to flood and the mine portals and

ventilation raises will be collapsed or blocked. The secondary portal at elevation 1,650 m will be

hydrostatically sealed with an engineered bulkhead. The primary portal at elevation 1,860 m will

be sealed to prevent surface water from entering the mine.

Infrastructure would be removed and disturbed sites re-graded to natural slopes. The access

roads would be deactivated in accordance with the Forest Practice Code.

All underground development rock would be placed as backfill during the mining process prior to

closure.

2.9.2 Access Road and Power Line Facilities

It is anticipated that bridges and culverts will be removed from the access roads. Additionally, all

crossing sites where bridges and culverts are removed will be ditched and protected to avoid or

minimize erosion. Organic material will be spread on the road surface and the road will be re-

vegetated as required.

Power line facilities will be removed from the BC Hydro interconnection to the mine site.

2.9.3 Mill and Ancillary Structures on-site

All Project structures will be decommissioned and removed from the site subsequent to the

cessation of mining operations. All explosives, explosive magazines, fuel, and fuel containers

will also be removed from the site at closure.

Concrete slabs, footings, and retaining walls will be taken apart by a hydraulic excavator

outfitted with a rock-breaker. Concrete fragments will be placed underground.

After removal of the processing building, equipment, and foundations, a soil sampling program

will be conducted in the immediate vicinity.

2.9.4 Tailings Facilities

Preliminary planning for site restoration activities for the TMF include placing a 1 m thick

granulated cover over the TMF to provide erosion protection and to minimize infiltration. Covers

will be graded to create natural drainage to reduce erosion.



Page 22 of 76

2.9.5 Environmental Monitoring

During operation, an environmental monitoring program will be implemented to provide a

baseline for post-closure-monitoring, should this be necessary. Details of the monitoring

program will be determined by further studies and in consultation with regulators and NLG.

2.10 Alternatives

Various mining, processing, and site development alternatives have been analyzed by past

owners and currently by IDM. The range of alternative means of carrying out the Project is

shown in Table 9.

Table 9: Summary of Alternative Means of Carrying Out the Project

Project Component Alternative Means

On-Site:

520 m long adit with a 1,000 tpd mill Considered alternate mill site near Bitter Creek (proposed by previous proponents), in conjunction with longer (7 km) adit. Not economically viable.

Processing Flotation concentrate followed by concentrate cyanide treatment has been tested. Resulting testwork recoveries indicated the option was not economically viable.

Flotation concentration has been tested extensively and off site concentrate sale potential evaluated. Due to a low concentration ratio, lower gold and silver recovery and high smelter treatment charges for a low gold grade pyritic concentrate, the option was not considered economically viable.

Surface warehouse and mine dry facilities

Must be proximal to the mill. No viable alternates.

Power line and step down facilities. Considered on-site LNG and diesel generation versus power line for the supply required. LNG & diesel Power costs for the life of the mine were 3 to 10 times higher than the proposed scheme.

Site office Must be proximal to the mill during operations. No viable alternates.

Access road from existing road along Bitter Creek

Road access is the only viable access. Must connect to the existing road, and avoid crossing Bitter Creek for safety reasons.

Design and detailed siting will be informed by environmental and terrain studies

Water Treatment Facility Location between Hartley Gulch and Otter Creek may be considered.



Page 23 of 76

Project Component Alternative Means

Tailings management facility Roosevelt Creek area considered and rejected because of environmental risk, geotechnical risk, and economic viability.

Bitter Creek alternate sites down valley considered but not chosen because of proposed mine layout and mill location.

Surface Maintenance Shop Must be proximal to the mill during operations. No viable alternates.

Major off-site components consist of the following items:

Project offices in Stewart, BC No alternate considered.

Warehouse in Stewart, BC No alternate considered. Shared logistics with the Project office and proximity to the mine site are important.

2.11 Proposed Development Schedule

2.11.1 Environmental Assessment Schedule

The preliminary schedule for Project approvals and development is shown in Table 10. Baseline

studies and consultation activities are already underway and the design concept and preliminary

engineering has continued since completion of the Preliminary Economic Assessment in 2014.

Baseline work is anticipated to be complete by late-2015. This schedule should allow the

submission of the Application for an EAC in the first quarter of 2016. Updates to this schedule

will be prepared as dialogue with the BC EAO develops following submission of the Project

Description.

Early engagement and Pre-Application consultation was begun in 2014 and is anticipated to

continue throughout the EA process.

Table 10: Anticipated Environmental Approvals and Project Development Schedule

Activity 2014 2015 2016 2017 2018

Preliminary design

Baseline studies

Draft Application Information Requirements Consultation and Review

Application Submitted

Application Screening

Application Review Period (180 days)



Page 24 of 76

Activity 2014 2015 2016 2017 2018

EAC decision

Project Permits and Authorizations

Construction

Start Operations

2.11.2 Project Development Schedule

Following receipt of approvals and permits, the Project will be developed through a 9 – 10

month construction period as follows:.

Construction will begin with the construction of the proposed access road to the existing tote

road to the upper portal. The lower portal will also be established to drive the incline, develop

the main ventilation raise and central deposit pass.

The electrical power line will be completed following with the road construction period. All

surface infrastructures would also be completed, including:

Underground Mine Development:

o One new portal and an existing portal;

o Extension of stopes and underground workings;

Mineral Processing Facilities, including:

o A new 1000 tpd mill;

Waste Management Facilities:

o Temporary waste rock storage area;

o New tailings management facility including;

o Tailings dam;

o Tailings pond;

o Tailings drainage control structures; and

o Tailings operations.

Water Management Facilities

o Water Diversions

o Water treatment facility (if required);

New surface warehouse and mine dry facilities;

Concrete batch plant (construction-phase only);

New fuel and explosives storage facilities;

New power line and step down facilities on-site;

New site offices and assay lab;

Upgraded and new on-site access;

New sewage and septic works; and



Page 25 of 76

New surface maintenance shop.

The main activities anticipated at each stage include:

Construction:

o Clearing and grading for the upgrade and construction of the access road and power line

right of ways;

o Construction of watercourse crossings for the access road and power line;

o Batch plant for concrete to be used for the foundations of civil infrastructure;

o Blasting;

o Construction of drainage facilities for surface water;

o Installing structures for mill, warehouse, and other surface infrastructure; and

o Environmental monitoring.

Operation:

o Grading and brushing as required to maintain road and power line right of ways;

o Mineral processing mill;

o TMF operation and ongoing reclamation;

o Water management facilities (water diversions and water treatment facility); and


Decommissioning:

o Backfilling;

o Removal of surface structures and concrete foundations;

o Deactivation of road and power line right of ways, including the removal of bridges and

culverts;

o Soil sampling;

o Granulated cover over TMF; and


Operations will continue for approximately 5 years with the possibility of an additional 2 years

depending on exploration success and metal prices. Mine site decommissioning would occur in

the year post-cessation of operations and full closure of the property would occur following the

completion of decommissioning followed by post-closure activities and monitoring. The

anticipated operations, decommissioning, and closure schedule is shown in Table 11.

Table 11: Anticipated Operations, Decommissioning, and Closure Schedule

Activity 2018 2019 2020 2021 2022 2023 2024 2025

Operations

Decommissioning

Full Closure



Page 26 of 76

3 EXISTING ENVIRONMENT

Detailed baseline studies were completed at Red Mountain from 1990 to 1997, including

ML/ARD characterization and baseline water quality, climate, hydrology, hydrogeology, wildlife,

vegetation, and fish studies. Data up to 1994 was presented in the draft Project Development

Application Report, which was submitted for regulatory review. However, the application was

withdrawn following the take-over of Lac Minerals by Barrick Gold and the EA was not

completed. Contemporary baseline studies were initiated for the Project in the spring of 2014,

and these will be augmented by data from these earlier studies in the EA. A summary of

baseline environmental conditions is presented in the following section.

3.1 Physical Environment

3.1.1 Climate

The Project area is at a high elevation and experiences snow cover for more than half the year;

though the parts of the access road at the lower elevations will have a longer snow free period

each year. A climate station was established close to the proposed mill site a number of years

ago by previous property owners but subsequently discontinued. IDM re-installed the climate

station in 2014. Historic monthly temperatures for the Red Mountain property are presented in

Table 12. Weather conditions in the Project area vary rapidly at all times of the year.

Table 12: Summary of Temperature Data for Bitter Creek Weather Stations

Elevation 565 m above sea level

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Annual

1993 13.2 13.0 10.3 5.9 -1.3 -0.9

1994 -0.8 -7.6 1.2 4.4 6.7 9.8 12.9 14.5 7.9 3.0 -3.2 -4.5 3.7

1996 9.1 11.7 2.4

Average -0.8 -7.6 1.2 4.4 6.7 9.5 12.6 13.8 9.1 3.8 -2.2 -2.7



1993 3.3 -4.3 -4.1

1994 -3.3 -9.8 -3.4 -0.7 1.5 3.9 8.5 10.8 3.6 -1.1 -7.1 -5.7 -0.2

1996 0.5 3.7 6.6

Average -3.3 -9.8 -3.4 -0.7 1.0 3.8 7.5 10.8 3.6 1.1 -5.7 -4.9



1993 0.0

1994 -6.0 -12.2 -6.8 -4.1 -1.9 1.0 5.7 7.7 -0.1 -4.3 -10.5 -8.9 -3.4

1996 -3.0 0.5 3.6 2.5 -1.0 -4.8

Average -6.0 -12.2 -6.8 -4.1 -2.5 0.7 4.7 5.1 -0.5 -3.0 -10.5 -8.9

Source: IDM (2014)



Page 27 of 76

As an indication of the climate of the lower parts of the Bitter Creek Valley and Bear River, the “Canadian Climate Normals 1981-2010 Station Data" published by Environment Canada, 2014, for Stewart are provided in Table 13. Stewart receives approximately 1,866.8 mm (73.5 in) per year of precipitation, much of it as snow, and an average yearly temperature of 6.1 °C (43.0 °F), according to Environment Canada.

Table 13: Climatic Normals for Stewart BC for 1981 to 2010

Climate Data for Stewart

Month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec Year

Record high 9.4 10.4 15.2 25.3 30.1 38.9 39.0 37.5 28.3 21.2 10.5 9.9 39.0

Record high °C 10.0 11.3 15.6 25.5 30.8 33.1 33.0 32.7 26.2 20.2 11.6 11.2 33.1

Average high °C

−0.5 2.3 5.8 11.0 15.8 18.9 19.8 18.8 14.7 8.9 2.7 0.1 9.9

Daily mean °C −3.0 −1.1 1.9 6.1 10.7 13.9 15.1 14.3 11.1 6.3 0.6 −2.1 6.1

Average low °C −5.5 −4.5 −2.0 1.1 5.5 8.9 10.4 9.8 7.4 3.6 −1.7 −4.3 2.4

Record low °C −24.5 −22.4 −19.5 −8.6 −2.8 0.7 4.6 2.8 −1.2 −12.2 −24.8 −25.6 −25.6

Precipitation mm

137.0 121.8 89.1 72.3 65.6 73.0 122.4

1,866.8

Rainfall mm 88.1 57.6 85.6 73.4 71.8 65.6 73.0 122.4

123.9 91.9 1,338.9

Snowfall cm

0.5 0.0 0.0 0.1 0.0

Avg. rainy days (≥ 0.2 mm)

11.4 10.3 15.8 16.4 16.1 15.4 16.4 17.4 20.2 23.2 16.1 12.0 190.6

Avg. snowy days (≥ 0.2 cm)

14.3 9.2 7.2 2.5 0.08 0.0 0.0 0.04 0.0 1.7 10.8 14.7 60.6

Mean monthly sunshine hours

119.8 157.7 145.0 138.1 126.5 85.2

985.4

Percent possible sunshine

10.8 14.9 20.1 28.2 31.2 27.7 26.3 27.1 22.2 12.3 7.9 6.5 19.6

3.1.2 Air Quality

The Project area is remote from human sources of air emissions and there has been no recent

monitoring of air quality. The main sources of emissions are from human activity proximal to

Stewart, traffic along Highway 37A, and exploration activity in the Bitter Creek Valley.

3.1.3 Noise

The noise environment of the Project area is characterized by natural background noise. No

monitoring of noise has been undertaken in the Project area. Other than periodic exploration

activity in the Bitter Creek watershed, the closest source of human noise is along Highway 37A.

3.1.4 Hydrogeology

Baseline information on groundwater is available from historic underground investigations and

sampling of springs and seeps, monitoring of the water level in the existing flooded adit from



Page 28 of 76

2003 to 2006, sampling of underground water quality from 2003 to 2007 and, most recently,

water quality sampling from a flowing exploration drill hole.

In general, groundwater is recharged at high elevations on the mountain and discharges to

creeks running of the valley walls and valley bottoms. Groundwater recharge was previously

estimated to be 400 mm/year, from net precipitation, with other additions from the ice fields or

snowfields. A majority of water from the Project area is expected to flow into Goldslide Creek

and other creeks running off the valley walls.

The groundwater system is fracture-controlled and the dominant flow paths will be joint sets and

possibly fault zones. These flow paths are expected to be short and shallow. Groundwater flow

is also influenced by existing exploration boreholes and underground workings.

3.1.5 Surface Water Hydrology

The Project site is located almost entirely within the catchment of Goldslide Creek. Goldslide

Creek flows into Bitter Creek, which then flows into the Bear River (Figure 3). The only Project

component no in the catchment of Goldslide Creek is a portion of the waste rock from the

existing exploration decline, which is located on the divide between the Goldslide Creek

catchment and Cambria Ice Field. The Cambria Ice Field flows towards the Bromley Glacier and

into Bitter Creek upstream of the confluence with Goldslide Creek. A number of other smaller

tributaries join Bitter Creek downstream of Goldslide Creek, including Rio Blanco and Roosevelt

Creeks. The Goldslide Creek catchment (2.2 km2) is small in comparison to the Bitter Creek

Catchment (253 km2).

The Project area is steep and large portions of the Bitter Creek and Bear River catchments are

glaciated, which strongly influences all of the major watercourses. Sediment loads, especially in

Bitter Creek, are very high during the summer. The bottom elevation and the alignment of the

streams change significantly from year to year, driven by seasonal runoff patterns and

fluctuating sediment loads. The highest mean monthly flows are typically observed in July and

August, while the lowest flows are typically observed in February. October is the rainiest month

and peak flows are often observed during this period.

Key sources of information on the hydrology include:

Data from a Water Survey of Canada (WSC) station (Station 08DC006) located on Bear

River immediately upstream of the Bitter Creek confluence;

Four hydrometric stations were installed for the Project in the early 1990s: Bitter Creek

(installed October 1990), Goldslide Creek (installed June 1993), Kitsault River (installed

January 1994), and Upper Roosevelt Creek (installed September 1993); and

Three new hydrometric stations installed in June 2014 at Goldslide Creek, Otter Creek and

Bitter Creek.



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3.1.6 Water Quality

3.1.6.1 Overview

Baseline water quality monitoring was carried out in Goldstrike Creek, Rio Blanco, Roosevelt

Creek, Bitter Creek, and the Bear River over the period 1993 to 2000. Further baseline

monitoring was initiated in May 2014 in support of the current EA Application. In addition, a

more limited number of baseline locations were monitored as part of a compliance monitoring

program completed from 2003 to 2013.

Water quality monitoring was also carried out in the vicinity of the exploration adit and waste

rock pile as a requirement of permits for exploration work and in support of ongoing studies on

the ML/ARD potential. This program included samples from the underground mine, field crib

tests, and the existing waste rock pile.

3.1.6.2 Baseline Conditions

Baseline samples were typically collected for analyses of routine parameters (pH, conductivity,

total dissolved solids, hardness, acidity, alkalinity, and sulphate), nutrients (ammonia, nitrate-,

and nitrite-nitrogen), and dissolved and total metals (BC Aquatic Life Suite). The results of the

baseline monitoring indicate highly variable water quality downstream of the mine.

Concentrations of sulphate and dissolved metal concentrations were elevated in comparison to

typical surface waters and concentrations of some parameters (notably copper) exceeded

freshwater aquatic life guidelines at several of the sampling locations, as shown in Table 14.

The exceedances in dissolved metal concentrations reflect the influence of natural

mineralization in the area, and were highest in stations closest to the deposit area. The more

recent monitoring data for Goldslide Creek (SRK 2012) indicates that downgradient water

quality monitoring in Goldslide Creek and Bitter Creek remains within historically-observed

ranges at these locations.

Strong seasonal variations are evident for both dissolved and total metal concentrations. The

highest dissolved concentrations are observed during low flow periods when there is less

dilution from snow and glacial meltwater, whereas the highest total metal concentrations are

found in Bitter Creek and the Bear River during summer months and are attributed to the high

suspended sediment content of the glacial meltwater during summer months.



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Table 14: Summary of Trace Elements with Concentrations in Excess of Freshwater Aquatic Life Guidelines

Station

Metals exceeding Guidelines* (average measured concentrations)

Metals exceeding Guidelines**

(maximum measured concentration)

Dissolved Total Dissolved Total

W3 - Goldstrike Creek Cd, Cu, Hg Ag, Al, Cd, Cr, Cu, Fe, Hg, Zn

Ag, Al, Cd, Cr, Cu, Hg, Se

Ag, Al, As, Cd, Co, Cr, Cu, Fe, Hg, Mn, Ni, Se, Zn

W5 - Bitter Creek u/s Highway Bridge

Cd, Cr, Hg, Se Ag, Al, As, Cd, Co, Cr, Cu, Fe, Hg, Mn, Se, Zn

Ag, Al, Cd, Cr, Cu, Hg, Se, Zn

Ag, Al, As, Cd, Co, Cr, Cu, Fe, Hg, Mn, Ni, Se, V, Zn

W11 - Rio Blanco Cd, Hg, Se Ag, Al, Cd, Co, Cr, Cu, Fe, Hg, Mn, Se, Zn

Ag, Al, Cd, Co, Cr, Cu, Hg, Mn, Se, Zn

Ag, Al, As, Cd, Co, Cr, Cu, Fe, Hg, Mn, Ni, Se, V, Zn

W17 - Bitter Creek u/s Roosevelt Creek

Al, Hg Ag, Al, As, Co, Cr, Cu, Fe, Hg, Mn

Ag, Al, Co, Cr, Hg, Se

Ag, Al, As, Co, Cr, Cu, Fe, Hg, Mn, Ni, Se, V, Zn

W18 - Roosevelt Creek

Cd, Hg Ag, Al, As, Cd, Cr, Cu, Fe, Hg, Se

Ag, Al, Cd, Cr, Cu, Hg, Se

Ag, Al, As, Cd, Co, Cr, Cu, Fe, Hg, Mn, Ni, Se, Zn

Notes: * Either the 30 day average or the maximum grab guidelines. ** Detection limits for Cd, Se and Hg were often higher than the guidelines, and reported exceedances may reflect values

that were below detection limits.

3.1.6.3 Monitoring of Existing Development Area

Monitoring results for the existing development area are presented in a series of annual

monitoring reports submitted to the MEM and MoE (SRK 2012).

Monitoring at the Marc Zone Waste Dump Seepage has been carried out from 2003 to 2013,

with a total of 30 samples collected from as many as five distinct locations during this period.

Most samples showed neutral to slightly acidic pH conditions (typically pH 5 to 8), moderately

elevated sulphate concentrations (typically 100 to 600 mg/L), and somewhat elevated metal

concentrations (e.g., zinc ranged from 0.005 to 2.8 mg/L, with a median of 0.036 mg/L).

Monitoring data for the field weathering cribs indicates that both cribs continue to have neutral

pH drainage and moderately elevated sulphate and metal concentrations.

The most recent monitoring data for the underground workings (JDS 2014) was provided to

MEM in a recent notice of work (NoW Tracking Number 100114526, July 15, 2014). The results

indicated neutral pH, relatively low sulphate concentrations (161 mg/L), and metal

concentrations well below Canadian MMER (e.g., zinc 0.013 mg/L). These results are

consistent with previous monitoring data for the underground mine water.

The water quality of studies provide an historical basis for assessing change in water quality,

while monitoring of the Marc Zone Waste Dump and the rock cribs informs further assessment

of the conditions in the watershed related to human activity associated with the Red Mountain

property.



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3.1.7 Surficial Geology and Terrain

The Project area lies in the Boundary Ranges of the Coast Mountains of northwest British

Columbia, on the western margin of the Intermontane Belt. There are two primary stratigraphic

assemblages present in the Stewart area and Bitter Creek Valley. From oldest to youngest they

are: Middle and Upper Triassic clastic rocks (mudstones, siltstones, sandstones and

conglomerates) of the Stuhini Group and the Lower and Middle Jurassic volcanic and clastic

rocks (pyroclastic rock, lapilli, tuff, and conglomerates) of the Hazelton Group. A series of

younger intrusive rocks are present in the Bitter Creek Valley. These younger intrusive rocks

were intruded up through the older sedimentary rocks. The intrusive rocks range from granite

and diorite assemblages to gabbros, these include the Goldslide Intrusion, Bromley Glacier

Pluton, and the Bitter Creek Pluton. The Goldslide Intrusion located at the Red Mountain

operations has a strong spatial relationship with the gold-silver mineralization being targeted.

The terrain is characterized by high relief glaciated valleys, with the Cambria Ice Field on the

east, west, and southern flanks of Bitter Creek Valley (above the Project area). The Bromley

Glacier extends down from the ice field into the Bitter Creek Valley to just below the Project

area. In the last decade the Bromley Glacier and the Cambria Ice Field have retreated several

hundred meters leaving the whole lower and upper valley slopes nearly completely ice free.

The surficial geology of the Bitter Creek Valley consists of unconsolidated glacial (moraine/till)

deposits, colluvium (rubble, slide debris, rockfall, and talus slopes), glaciofluvial (glacial

meltwater deposits), and fluvial (mostly coarse gravel) sediments of varying thickness. Soil

development is very thin and sparse due to the steep slopes, high precipitation, and relatively

recent exposure to weathering. Evidence of past slope movements are common within the

valley from rock fall areas, exposed raveling slopes, gullying, translational failures, and

rotational slides in the thick unconsolidated materials.

Debris flows and debris floods are known to have occurred within the tributary creeks flowing

into Bitter Creek resulting in washouts of the pre-existing road at the valley bottom and

increased sediment supply to Bitter Creek. Similarly, flooding is common in the valley and has

recently resulted in the scouring and widening of the active channel as well as destroying the

Highway 37A bridge downstream. Like all of the mountainous valleys in the area, the valley is

prone to avalanches throughout the fall, winter, and spring months. Multiple avalanche tracks

are visible down to the valley bottom on the main slopes and on slopes funnelling into the area

drainages. The Bitter Creek Valley is a very dynamic terrain with multiple slope and fluvial

processes that are ongoing.

3.2 Biological Environment

3.2.1 Terrestrial Ecology

The Bitter Creek drainage consists of four Biogeoclimatic Ecosystem variants: Coastal Western

Hemlock Wet Maritime Subzone (CWHwm); Mountain Hemlock Moist Maritime Windward



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Variant (MHmm1); Mountain Hemlock Moist Maritime Parkland Variant (MHmmp); and Coastal

Mountain-heather Alpine Zone Undifferentiated (CMAun).

The CWHwm is the most northerly subzone of the CWH and occurs mostly on the inside of the

Alaska Panhandle from Portland Inlet north to the Yukon border, at elevations between sea

level and approximately 600 m (Banner et al, 1993). Located in proximity to the Pacific Ocean,

this subzone receives large amounts of precipitation and relatively warm temperatures. It is

characterized by very heavy snowfall, steep, rocky terrain, and low plant species diversity

(Banner et al, 1993). Western hemlock (Tsuga heterophylla) and Sitka spruce (Picea sitchensis)

are the dominant tree species in this subzone. Western red cedar (Thuja plicata) and yellow

cedar (Camaecyparis nootkatensis) are infrequent. Amabilis fir (Abies amabilis) is absent. The

understory typically includes Alaskan and oval-leaved blueberry (Vaccinium alaskaense and

Vaccinium ovalifolium), as well as false azalea (Menziesia ferruginea), bunchberry (Cornus

canadensis), and five-leaved bramble (Rubus pedatus). The CWHwm may have submontane

and montane variants, but these have not yet been formally described (Banner et al, 1993).

Generally, the MH zone occurs in subalpine areas above the CWH zone and can be

distinguished from the CWH by the dominance of mountain hemlock over western hemlock. The

MHmm1 is found on the windward western slopes of the Coast Mountains at an elevation

between 800 m and approximately 1,200 m (Banner et al, 1993). Dominant tree species include

mountain hemlock (Tsuga mertensiana), amabilis fir, and western hemlock (in the lower

elevations), as well as yellow cedar (mainly on seepage sites). Subalpine fir (Abies lasiocarpa)

is generally absent except in areas of severe cold air ponding. Understory species include

Alaskan blueberry and black huckleberry (Vaccinium membranaceum), with pipecleaner moss

(Rhytidiopsis robusta) and lanky moss (Rhytidiadelphus loreus) common in the moss layer

(Banner et al, 1993).

The MHmmp occurs above the MHmm1 variant, and occupies the transition from tree-line to

true alpine tundra. This variant is distinguished by discontinuous forest cover interspersed with

subalpine heath, lush herbaceous meadows, and subalpine bogs and fens (Banner et al, 1993).

Common tree species are mountain hemlock, subalpine fir, and yellow cedar. The understory

vegetation in this parkland subzone features a variety of alpine and subalpine plants including

pink mountain-heather (Phyllodoce empretriformis), white mountain-heather (Cassiope

mertensiana), and partridgefoot (Luetkea pectinata).

The CMA lies above the MH zone in the coastal ranges, at elevations between 1,200 m and

1,600 m (and up to 2,400 m). This zone is treeless, but tree species can occur at lower alpine

elevations in stunted or Krummholz form (mostly mountain hemlock, yellow cedar, and

subalpine fir). Evergreen dwarf shrubs are characteristic of the coastal CMA and include pink

and white mountain-heathers, partridgefoot, and crowberry (Empetrum nigrum). Alpine herb

meadows may develop at middle and lower alpine elevations on well-drained sites with deep

soils, in seepage areas, or along alpine creeks. Typical herb species include arrow-leaved

groundsel (Senecio triangularis), Sitka valerian (Valeriana sitchensis), Indian hellebore

(Veratrum viride), subalpine daisy (Erigeron peregrinus), arnicas, louseworts, paintbrushes,

subalpine buttercup (Ranunculus eschscholtzii), and arctic and Nootka lupines (Lupinus arcticus



Page 33 of 76

and L. nootkatensis) (Banner et al, 1993). Non-vegetated features of the CMA include glaciers,

bare rock, boulder fields, and moraine.

Wildlife species likely occurring, or known to occur within the Project area, include both large

and mid-sized carnivores (e.g., grizzly and black bear, wolf, and wolverine), smaller furbearers

(e.g., American marten, red squirrel, and hoary marmot), mountain goat, a variety of bird

species (e.g., small passerines, raptors, ptarmigan, and grouse), and amphibians (e.g., western

toad).

The draft Nass South Sustainable Resource Management Plan (MFLNRO, 2012) has identified

mountain goat Ungulate Winter Ranges throughout the Bitter Creek drainage to manage

important wintering habitat for the species. In addition, suitable habitat for Northern Goshawk

and lower elevation ecosystem networks has been spatially identified.

3.2.2 Fish and Fish Habitat

The aquatic environment most likely to be influenced by the proposed Project includes the Bitter

Creek drainage. All currently proposed mining-related infrastructure (e.g., waste dump and

storage tailings facility) and operations will be restricted to the Goldslide Creek drainage, a

tributary to Bitter Creek located in the headwaters of the watershed.

Stream order hierarchy is a way to define the size of perennial (a stream with water its bed

continuously throughout the year) and recurring (a stream with water in its bed only part of the

year) streams. A first order stream is the smallest of streams and consists of small tributaries. In

addition, first and second order streams generally form on steep slopes and flow quickly until

they slow down and meet the next order waterway. First through third order streams are also

called headwater streams and constitute any waterways in the upper reaches of the watershed.

Unlike the smaller order streams, the medium and large rivers are usually less steep and flow

more slowly. They do, however, tend to have larger volumes of runoff and debris as it collects in

them from the smaller waterways flowing into them.

Goldslide Creek, a short, 2.4 km-long, first-order watercourse, is one of the many tributaries of

Bitter Creek and is located in the headwaters near the foot of Bromley Glacier. There, Bitter

Creek is a 17 km-long, fourth order stream that flows west and drains into Bear River. Bear

River is a large, 38 km-long, fifth order, fish-bearing watercourse that makes up an important

component of the Nass watershed.

The Bear River is approximately 14.5 km from the confluence with Bitter Creek draining

downstream to the marine environment in Stewart, BC.

Historical fisheries data for the Bitter Creek drainage (Rescan 1993), suggests there is limited

usage and available/usable fish habitat as well as a potential barrier to upstream fish migration

characterized near Hartley Gulch. No fish (at the time of study) were observed above this

apparent obstruction. Furthermore, Dolly Varden (Salvelinus Malma) was found to be the only

fish species inhabiting Bitter Creek as well as the lower reaches of Roosevelt Creek (a tributary



Page 34 of 76

to Bitter Creek). Fish captured during the Rescan (1993) study appeared to be in good health.

There is no historical fisheries information available for Goldslide Creek.

The draft Nass South Sustainable Resource Management Plan (MFLNRO, 2012) characterizes

the Bear River as encompassing very high fish values, providing habitat for all species of Pacific

Salmon including Coho Salmon (Oncorhynchus kisutch), Chum Salmon (O. keta), Sockeye

Salmon (O. nerka), Chinook Salmon (O. tshawytscha), and Pink Salmon (O. gorbuscha),

steelhead (O. mykiss), and resident populations of coastal cutthroat trout (O. clarki clarki),

rainbow trout (O. mykiss), Mountain Whitefish (Prosopium williamsoni), large-scale sucker

(Castostomus macrocheilus), redside shiner (Richardsonius balteatus), peamouth chub

(Mylocheilus caurinus), northern pikeminnow (Ptychocheilus oregonensis), Pacific lamprey

(Entosphenus tridentatus), and eulachon (Thaleichthys pacificus). The abundance and diversity

of salmon migration to spawning beds make the Nass watershed provincially, nationally, and

internationally significant.

The Bear River is well known to provide critical habitats for salmon and steelhead. Sockeye, in

addition to the other Pacific salmon and steelhead species in the watershed, are important to

Nisga’a citizens who fish in the area for food, social and ceremonial purposes. The region is

also inhabited by both bull trout (Salvelinus confluentus) and Dolly Varden (S. malma), both of

which are blue-listed in the Province of BC (i.e., designated as threatened in their present

range). Bull trout are a key predator in the aquatic food chain and a valuable seasonal food fish

to Nisga’a. Bull trout are also important sport and food fish to local residents. The Bear River

has also been reported to contain eulachon (smelt); however, very little is known and runs are

not regular (COSEWIC 2013). The Nass/Skeena River populations of eulachon have been

designated as Species of Special Concern by COSWIC (2013); however, this species is not

protected under the federal Species at Risk Act (SARA). All of the fish species in Bear River

may also be present in Bitter Creek given that no barrier exists between these two

watercourses; however, their extent and distribution in Bitter Creek is currently unknown.

A fisheries and aquatic baseline study program (utilizing updated regulatory standards) was

initiated for the Project in 2014 to provide information on drainages in the area of the proposed

Project, including Bitter Creek and key tributaries (e.g., Roosevelt Creek) and Bear River, that

may be affected by Project components and activities (e.g., power line, mine site, waste rock

and tailings, effluent discharge).

3.2.3 Wildlife, Avian Species, and Species at Risk

North American and Provincial databases were searched to identify wildlife species that

potentially occur within the Project area. Fifty-eight species, including 2 amphibians, 45 birds,

and 11 mammals, were identified as a traditional use or conservation concern (Table 15).

Provincially listed species include 33 blue-listed species and 12 red-listed species. In addition,

13 species are listed as identified wildlife. Species listed under the Committee on the Status of

Endangered Wildlife in Canada (COSEWIC) include 13 species listed as Species of Special

Concern, 7 as Threatened, and 1 as Endangered. There are 14 federally protected species



Page 35 of 76

listed under Schedule 1 of the federal Species at Risk Act (SARA) and 1 species listed under

Schedule 3 of SARA as a species of special concern.

The species list in Table 15 is a compilation of species of traditional use or of conservation

concern that occur in the general area around Stewart BC which, because of its proximity to the

Pacific Ocean, is influenced by a marine environment. It is important to note that species

diversity is relatively lower at the higher elevations near the mine site when compared to the

lower elevation areas within and adjacent to the Project Area. Important species in terms of

conservation status, regional importance or of local, social, and/or economic significance are

expected to either reside or seasonally use the Project area. Some of these key species for the

region include: moose, mountain goat, grizzly bear, wolf, wolverine, fisher and other furbearers,

hoary marmot, western toad, pacific tailed frog, and both non-migratory and migratory birds

(including waterfowl, raptors, and songbirds).

Table 15: Anticipated Wildlife Species of Conservation or Traditional Use Concern that are Known to Occur or that May Occur in the Project Area

Species Scientific Name

Conservation Status

Migratory1

Likelihood of Occurrence

4 BC List

Identified Wildlife

COSEWIC2 SARA

3

Amphibians

Western Toad Bufo boreas Blue SC 1 P

Pacific Tailed Frog

Ascaphus truei Blue Y SC 1 P

Birds

Sooty Grouse Dendragapus fuliginosus

Blue N P

Band-tailed Pigeon

Patagioenas fasciata

Blue SC 1 Y LP

Common Nighthawk

Chordeiles minor

Yellow T 1 Y P

Olive-Sided Flycatcher

Contopus cooperi

Blue T 1 Y LP

Barn Swallow Hirundo rustica Blue T Y P

Rusty Blackbird Euphagus carolinus

Blue SC 1 Y P

Yellow-Billed Loon

Gavia adamsii Blue NAR Y LP

Horned Grebe Podiceps auritus

Yellow SC Y LP

Western Grebe Aechmophorus occidentalis

Red Y SC Y LP



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Conservation Status

Migratory1


4 BC List

Identified Wildlife

COSEWIC2 SARA

3

Double-Crested Cormorant

Phalacrocorax auritus

Blue NAR Y LP

Pelagic Cormorant, pelagicus subspecies

Phalacrocorax pelagicus pelagicus

Red Y LP

Brandt's Cormorant

Phalacrocorax penicillatus

Red Y LP

American Bittern Botaurus lentiginosus

Blue Y Y LP

Trumpeter Swan Cygnus buccinator

Yellow Y NAR Y P

Tundra Swan Cygnus columbianus

Blue Y LP

Brant Branta bernicla Blue Y LP

Canada Goose, occidentalis subspecies

Branta canadensis occidentalis

Red Y LP

Cackling Goose Branta hutchinsii

Blue Y LP

Long-tailed Duck Clangula hyemalis

Blue Y LP

Surf Scoter Melanitta perspicillata

Blue Y LP

Northern Goshawk, Laingi Spp

Accipiter gentilis laingi

Red Y T 1 P

Rough-Legged Hawk

Buteo lagopus Blue NAR Y LP

Peregrine Falcon, Pealei Ssp

Falco peregrinus pealei

Blue SC 1 Y LP

Peregrine Falcon, Anatum Ssp

Falco peregrinus anatum

Red SC 1 Y LP

Swainson's Hawk Buteo swainsoni

Red Y LP

Gyrfalcon Falco rusticolus Blue NAR Y P



Page 37 of 76


Conservation Status

Migratory1


4 BC List

Identified Wildlife

COSEWIC2 SARA

3

Sandhill Crane Grus canadensis

Yellow Y NAR Y P

American Golden-Plover

Pluvialis dominica

Blue Y LP

Red Knot Calidris canutus

Red E/T 1 Y LP

Wandering Tattler

Tringa flavipes Blue Y LP

Upland Sandpiper

Bartramia longicauda

Red Y LP

Short-Billed Dowitcher

Limnodromus griseus

Blue Y LP

Red-Necked Phalarope

Phalaropus lobatus

Blue SC Y P

California Gull Larus californicus

Blue Y P

Caspian Tern Hydroprogne caspia

Blue NAR Y LP

Tufted Puffin Fratercula cirrhata

Blue Y LP

Horned Puffin Fratercula corniculata

Red Y LP

Marbled Murrelet Brachyramphus marmoratus

Blue Y Y LP

Cassin's Auklet Ptychoramphus aleuticus

Blue Y SC Y LP

Common Murre Uria aalge Red Y LP

Snowy Owl Bubo scandiacus

Blue NAR Y LP

Western Screech-Owl

Megascops kennicottii

No Status

T 1 N P

Short-Eared Owl Asio flammeus Blue SC 1 Y P

Lewis's Woodpecker

Melanerpes lewis

Red Y T 1 Y LP

Mammals

Fisher Martes pennanti

Blue Y P



Page 38 of 76


Conservation Status

Migratory1


4 BC List

Identified Wildlife

COSEWIC2 SARA

3

Least Weasel Mustela nivalis Yellow P

Wolverine, Luscus Ssp

Gulo gulo luscus

Blue SC P

Grizzly Bear Ursus arctos Blue Y SC HP

Black Bear Ursus Americanus

Yellow K

Mountain Goat Oreamnos americanus

Yellow Y K

Moose Alces americanus

Yellow HP

Hoary Marmot Marmota caligata

Yellow P

Red Squirrel Tamiasciurus hudsonicus

Yellow HP

Keen's Myotis Mytois keenii Blue Y DD 3 LP

Northern Myotis Mytois septentrionalis

Blue E 1 LP

1 Per the Migratory Birds Convention Act, 1994

2 SC - Special Concern; T - Threatened; NAR - Not At Risk; DD - Data Deficient

3 1 - Schedule 1; 3 - Schedule 3

4 K - Known (100%), HP - Highly Probable (>75%), P – Probable (50 - 75%), LP - Low Probability (25 - 49%), U – Unlikely <25%)

3.3 Human Environment

The Project is located in northwest British Columbia amid the Boundary Ranges of the Coast

Mountains, west of the Nass Basin. Highway 37A is the only road linking the District of Stewart,

the community nearest the Project area, to the BC communities of Smithers and Terrace and

north toward the Yukon Territory via Bear Pass. The community of Hyder is approximately 4 km

south of Stewart, in Alaska, USA. Smithers and Terrace are approximately 270 km and 240 km

by road from Stewart, respectively. Four Nisga’a villages (Figure 4) proximal to the Project area

are:

Gitlaxt’aamiks - approximately 170 km from Stewart by road;

Gitwinksihlkw - approximately 180 km from Stewart by road;

Laxgalts’ap - approximately 215 km from Stewart by road; and

Gingolx - approximately 245 km by road from Stewart.



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Figure 4: Nisga'a Lands and Communities



Page 40 of 76

The Project is located approximately 12 km north along the Bear River Valley and then 16 km

southeast along the Bitter Creek Valley, for a total distance of 28 km northeast of Stewart.

Stewart is served by a small airport and is located in the estuary at the head of the Portland

Canal. The Portland Canal provides marine transport access to Stewart, which is the most

northerly ice-free port in Canada.

The north-western region of British Columbia is dominated by resource extraction, primarily the

extraction of mineral and timber resources. Consequently, economic activity, population levels,

and social and community services fluctuate with the level of mining and forestry activity.

There is a growing tourist industry in the Bear River Valley and Stewart area, focussed on

glacier tours, wildlife viewing, and fishing.

A new project, the Kerr-Sulphurets-Mitchell Project (KSM), has been proposed by Seabridge

Gold and it has recently received approval (through an Environmental Assessment Certificate

and a Mines Act permit) by the Government of BC and the Government of Canada to begin

development in an area 65 km northwest of Stewart. In addition, the Brucejack Project, owned

by Pretium Resources Inc., approximately 65 km northwest of Stewart, is currently in the

regulatory review and approvals process.

3.3.1 Land and Resource Use

The Project is located within the Regional District of Kitimat-Stikine.

The closest municipal boundary is that of the District of Stewart. Stewart district boundaries lie

within the Bear River Valley. An elected Mayor and Council govern Stewart, with elections held

every three years.

Placer Gold was first discovered in Bitter Creek in the late 19th Century, with small scale mining

and mineral exploration throughout the 20th century. The region has a rich history of mining

which includes past and present operations such as the Premier Gold Mine, the Granduc

Copper Mine, the Dolly Varden Mine operated by Dolly Varden Silver Corporation, Eskay Creek

Mine operated by Barrick Gold Corporation, and the Johnny Mountain Underground Mine

operated by SnipGold Corporation.

Forestry production in the Project area is limited by steep terrain, climatic conditions, and thin,

infertile soil. Poor regional forestry values, low timber quality, and long haulage distances

combine to limit the economic viability of timber harvesting in the Stewart-Alice Arm area.

However, the lower portions of Bitter Creek and Roosevelt Creek Valleys were commercially

logged in the 1960’s. Agricultural potential in the Project area is also limited by poor soil

conditions, marketing restrictions, and short growing seasons (Royal Oak, 1996).

Other resource interests overlapping with the Project area include one guide outfitter

concession (601036) and two traplines (TR0614T101, TR0614T094), as well as one

commercial recreation licence (910116) for a heli-skiing operation.



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The Project area lies within the boundaries of the Nass South Sustainable Resource

Management Plan (MFLNRO, 2012), in the Bear (Intermediate) landscape unit.

The Project is within the Bear River and Bitter Creek watersheds and within the Terrace Water

Management Precinct of the Prince Rupert Water Management District within the Northern

Water Management Service region.

3.3.2 Aboriginal Land Use

The Project falls within the Nass Wildlife Area, an area where Nisga’a has Treaty interests, as

out in the NFA. Pursuant to the NFA, Nisga’a has Treaty rights to the management and

harvesting of fish and wildlife within the Nass Wildlife Area.

Sgamagunt, formerly Scamakounst Indian Reserve 19, is the nearest parcel of Category A

Land, as defined in the NFA, and is held by Nisga’a as estate in fee simple. Sgamagunt is

situated on the east bank of the Bear River, approximately 500 m across from Stewart, BC.

Waters draining from Red Mountain flow into Bitter Creek, which in turn flows into the Bear

River upstream of Sgamagunt.

Current information suggests that no other Aboriginal Groups will be potentially affected by the

Project. However, IDM will consult with other Aboriginal Groups should new information surface

during the regulatory review and approvals processes.

Nisga’a citizens are closely tied to the land and practice traditional and cultural activities,

including seasonal resource harvesting of terrestrial and marine plants, hunting and trapping

wildlife, and fishing. The NLG website outlines the importance of the land to the Nisga’a’s

culture, governance, and survival. NLG stresses the importance of the Nisga’a’s traditional

system of land ownership which “sets the economic rules” and the “social foundation” for their

society.

They write:

“The system clearly laid out the rules of access to the rich economic resources of

the Nisga'a lands — who has right to go where — and thereby protected against

internal strife. People knew the rules for using an area and proper behaviour on

the land; access to particular land areas and its resources weren't a matter of

battles, you simply had to ask. This is the kind of control and laws which are, in

reality, the essence of government. For the Nisga'a the laws of government and

property are integral to the structure of society and family relation,” (Nisga’a

Lisims Government, no date, a).

NLG also writes about the importance of the land as the staging ground of the Nisga’a’s

traditional history stories (adaawak), as the territory of the matrilineal houses (wilp), and the

direct relationship of Nisga’a citizens to the land and animals by way of the four tribes (pdeek):

Raven/Frog (Ganada), Wolf/Bear (Laxgibuu), Killer Whale/Owl (Gisk’aast), and Eagle/Beaver

(Laxsgiik). Traditionally, under the system of Ango’oskw (resource holding), a Nisga’a hunter or



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fisherman would seek permission of the Hereditary Chief of the wilp to use the natural resources

found in their territory. This process was “an important display of kwhlixhoosa’anskw (respect).”

Pursuant to the Nass Area Strategy, implemented in 2008 in response to resource development

in the Nass Area, “only environmentally sound resource development projects that are

consistent with Nisga’a Treaty rights will proceed” (Nisga’a Lisims Government, no date).

NLG states that it strives for sustainable prosperity and self-reliance, working with partners to

build;

Forest products;

Fish & Seafood products;

Telecommunications;

Hydroelectric power generation;

Mineral resource development;

Land leases; and

Tourism.

In addition to the traditional cultural importance of the land, NLG is active in modern economic

resource development including, forestry tenures, commercial recreation, angling licences, and

traplines.

The Project also lies within the asserted traditional territories of Skii km Lax Ha and MNBC. Skii

km Lax Ha and MNBC have asserted Aboriginal rights and interests in the area, including

hunting, trapping, and gathering.

3.3.3 Viewscapes

The Project lies in the upper part of the Bitter Creek Valley adjacent to the Cambria Ice Field

(above the Project area) and the Bromley Glacier (below the Project area) at elevations ranging

between 1,500 and 2,000 m, in an area characterized by rugged steep terrain. In the lower part

of the Bitter Creek Valley, the views comprise forested landscapes, but in the upper and higher

elevation parts of the drainage, view are of exposed and open terrain, some recently exposed

by the retreating ice field. The Project site is not visible to residents of Stewart nor to travellers

on Highway 37A.

3.3.4 Archaeological and Heritage Resources

While IDM is not aware of any known archaeological or heritage resource values in the Project

area, the presence of Aboriginal Groups in the Bear River basin is well documented. The extent

to which Aboriginal Groups used the Bitter Creek Valley is less well known at this time.

However, IDM Mining will undertake an Archaeological Overview Assessment and, if necessary,

an Archaeological Impact Assessment to confirm whether or not any values are present.



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Further, IDM will work with NLG with respect to the collection of Traditional Knowledge and Use

Information to further identify potential economic, social, and cultural Project effects. Mitigation

measures will be developed in consultation with NLG throughout the EA.

3.3.5 Aboriginal, Commercial, and Recreational Fishery and Fishing Areas

The Project area lies adjacent to the Cambria Ice Field and the Bromley Glacier in the Bitter

Creek Valley at elevations ranging between 1,500 m and 2,000 m. As a result, this area is

characterized by rugged steep terrain with high-energy streams and limited fish habitat, and has

not been known to support Aboriginal, commercial, or recreational fisheries. Additionally, there

are no known downstream Aboriginal, commercial, or recreational fishing areas that could be

potentially impacted by the Project.

IDM will work with NLG to “assess the effects of the Project on the existing and future economic,

social, and cultural well-being of Niga’a citizens who may be affected by the Project,” as per

NFA Chapter 10, section 8(f). Mitigation measures will be developed in consultation with NLG

throughout the EA.

3.4 Current Economics

Major industries operating around the District of Stewart include tourism, mining exploration,

mining operations, and logging. The Stewart World Port and Stewart Bulk Terminals operate out

of the port of Stewart, which is North America’s most northern ice-free port and a hub for

shipping to Alaskan and Asian markets. Roadways connect Stewart to other transportation hubs

in British Columbia and North America.

Businesses in Stewart generally rely on resource industry companies and tourism opportunities

related to the many hiking trails and outdoor recreation activities in and around Stewart.

3.4.1 Demographics

Prior to 1914, the population of Stewart was reported to be in the order of 10,000 people (BC

Travel, 2014). By 2001 the population had declined to approximately 660 people and declined

further to 496 in 2006 (Government of Canada, 2006). In 2011, the population of the District of

Stewart was 494 (Government of Canada, 2011).

At the time of the 2006 Canadian census, 32.4% of the population held a high school certificate

or equivalent and the majority of employment was in the trades and transportation sectors. The

unemployment rate was 8.2% (Government of Canada, 2006).

According to the District of Stewart’s Investment-Ready Community Profile, the largest

employers in Stewart are in the mining, petroleum resources, highway maintenance,

accommodation, and education, and health care industries.

Nisga’a has a total population of approximately 5,581 (Aboriginal Affairs and Northern

Development Canada, 2014 a, b, c and d). The majority (67%) live off-reserve. The on-reserve



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population predominantly live in four Nisga’a villages: Gitlaxt’aamiks, Gitwinksihllkw,

Laxgalts’ap, and Ginglox. A breakdown of the Nisga’a Nation population is provided below in

Table 16.

Table 16: Nisga’a Population Reported in July 2014

Nisga’a Nation Community On Reserve Population

Population on Other Aboriginal Reserves

Population Off-Reserve

Total Population

Gitlaxt’aamiks 474 51 915 1,440

Gitwinksihllkw 185 28 184 397

Laxgalts’ap 576 60 1,129 1,765

Ginglox 406 68 1,505 1,979

Total 1,641 207 3,733 5,581

Source: (Aboriginal Affairs and Northern Development Canada First Nation Profiles, July 2014)

3.4.2 Local Services

Stewart provides a number of community services including air services, road transportation to

the interior of BC, marine transport via the Portland Canal, water supply, sewage and waste

management facilities, health services, and policing and emergency services. There also exists

a range of business services, parks and recreation services, and services and facilities for

visiting tourists.

3.4.2.1 Health Services

The Stewart Health Centre, operated by Northern Health, provides care and outpatient services

including public health and social services, pre- and post-natal infant and childcare, and

emergency services. There are regularly scheduled day and afternoon shifts as well as a

physician on-call. The center provides emergency room services and a doctor's clinic and is a

member of the Rural Coordination Centre of BC. BC Ambulance operates land and air

ambulance services out of the Stewart Health Centre.

3.4.2.2 Police and Emergency Services

The Royal Canadian Mounted Police (RCMP) provides police services throughout the District of

Stewart. The nearest Canadian Coast Guard station is located in Prince Rupert.



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4 POTENTIAL PROJECT EFFECTS ON THE ENVIRONMENT

This section describes the principal potential effects of the Project on the physical, biological,

and human environments.

4.1 Physical Environment

4.1.1 Air Quality

Air emissions are not expected to be significant coming from vehicle and equipment use, dust

from road use and mining operations, diesel generators, and the mill. Air emissions might

include particulate matter, NOx, SOx, and greenhouse gas emissions. Minimal air emissions are

also anticipated from a waste incinerator that will be utilized to dispose of food waste,

packaging, and domestic waste.

Air emissions from these sources are anticipated during the construction, operation, and

reclamation of the mine. The emissions would not occur during the three coldest months of the

year during each year of construction and operations due to shutdown.

4.1.2 Noise

The principal sources of noise anticipated from the Project are vehicle and equipment use on

the existing roads, and the on-site tote roads, equipment onsite, and from the mill. The noise

sources would cease during the three coldest months of the year during both construction and

operations phases of the Project, due to shutdown.

Periodic helicopter use is anticipated during construction and operations for the nine months the

Project is active each year.

It is expected that helicopter use and vehicle use will be subject to requirements for wildlife

management plans applicable to the area, established jointly by the MoE and NLG.

4.1.3 Hydrogeology

Groundwater quality may be affected by ML/ARD of rocks exposed in the underground or from

backfill material. At the end of operations, the mine workings will be plugged and allowed to

flood, which will significantly reduce the potential for effects on groundwater quality from the

mine itself. Groundwater modeling will be completed to assess how the groundwater system

could change from operational dewatering, the level to which the mine will flood at the end of

operations, and, once flooded, the expected seepage rate out of the mine. The need for any

mitigation measures will be assessed in conjunction with receiving environment water quality

predictions. A Groundwater Monitoring Plan will be developed to allow confirmation of

predictions.



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4.1.4 Surface Water Hydrology

Potential effects on the surface hydrology include the construction of the TMF adjacent to the

Goldslide Creek, water diversions associated with the TMF, temporary waste rock piles and the

mill area, and the use and discharge of effluent from the process plant. The quantities of make-

up water are small in comparison to the total flows in Goldslide creek and are not expected to

result in appreciable changes to the flow in this creek. Changes in flows in Bitter Creek and

Bear River will be negligible.

4.1.5 Water Quality

As discussed in section 3.1.6, baseline concentrations of some trace elements exceed

guidelines for freshwater aquatic life as a result of natural mineralization in the vicinity of the

deposit as well as particulates from glacial meltwater. It is therefore expected that site-specific

water quality criteria will need to be developed for this Project.

Waste rock, exposed rock in the underground workings, tailings, and some of the cut and fill

areas along the on-site tote roads have been classified as potentially acid generating. A key

objective of the waste and water management plans will be to prevent the development of

ML/ARD during operations and after closure. The current plans are to backfill waste rock into

the underground workings and to install a hydrostatic bulkhead to flood the workings at closure.

The tailings will be deposited in a lined tailings management facility and will be covered at

closure.

It is estimated that the TMF water balance will be consumed by the mill operations with a minor

net deficient requiring surface water collection to be used intermittently for operations makeup

water. Further work is required to determine a final water balance and whether intermittent

discharge to the receiving environment would be required. Additional testwork during the

prefeasibility study will indicate if any potential discharge water quality will meet the Canadian

MMER.

Water quality modelling will be completed to assess the potential effects of the discharge on

down gradient and downstream water quality.

As there will be no accommodations on site, sewage treatment will be limited to site office

facilities. Sewage treatment will be conducted as a closed system of holding tanks that will be

pumped out as required. As such, no impact to water quality is anticipated from sewage

treatment or domestic water use.

4.1.6 Surficial Geology and Terrain

The Project area will be mapped for its surficial geology and terrain to provide a description of

the area’s terrain, terrain hazards, soil erosion potential and fluvial systems. The areas with

known instabilities will be identified, including their proximity to proposed works, estimated

magnitudes, runout, and their potential to adversely affect the Project or the environment.

Consideration of terrain hazards and surficial geology will be used to guide the placement of the



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access road up to the mine area so that it utilizes the lowest risk route. The design of the road

crossings will use information gathered from the fluvial assessments at the creek crossings so

they account for the potential power from future flooding, debris flows, and debris floods.

Avalanche areas will be identified so a management approach can be developed for the mine

access and facilities area.

4.2 Biological Environment

4.2.1 Wildlife and Vegetation

Minimal clearing of timber may be required for the construction of infrastructure (i.e., access

road and power lines). IDM estimates that up to 11 hectares of timber clearing will be required

over the entire project; primarily associated with access to the mine site.

Terrestrial wildlife and vegetation effects associated with the Project may include habitat

alteration and fragmentation; species displacement or disturbance; and mortality. These

concerns will be prevalent during both construction and operation; however, the extent of effects

will be dependent on the type of activity, location, seasonal timing, frequency, and downstream

effects associated with water quality. The risk assessment will look at the potential issues for

both the general location of the proposed Project and individual components of particular

infrastructure.

The use of the access road to the Project could expose wildlife to direct mortality due to traffic

collisions. The species most vulnerable to road-kill mortality in the Project area are the small,

slow-moving species such as amphibians, which are difficult for drivers to see. Mine operations

traffic will be confirmed as the Project develops. Access roads will be controlled to avoid the

potential for increased hunting opportunities within the Project area.

Wildlife uptake of heavy metals and other contaminants through the ingestion of surface waters

or dry deposition on plants may occur. However, these effects are expected to be limited as the

receiving surface waters within the Project area are not anticipated to have elevated heavy

metal concentrations due to mitigation measures and management of the tailings. The dry

deposition of particles with elevated metal content on plants will be minimal due to limited

fugitive dust events.

4.2.2 Fish and Fish Habitat

Bitter Creek, via Goldslide Creek, is the primary watercourse supporting fisheries that may be

affected by runoff from waste rock and tailings from the Project. However, historical and current

information suggests the upper-most reaches of Bitter Creek are non-fish bearing; it is believed

that the closest fish presence and habitat is approximately 6.5 km downstream from the

Goldslide Creek/Bitter Creek confluence, in the vicinity of Hartley Gulch. Ongoing field surveys

specific to fish distribution, abundance, and diversity will confirm and update historical

information. Along proposed rights-of-way, fish and fish habitat may be affected through

degradation of habitat by erosion, sedimentation, and clearing of riparian vegetation for road



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construction and use. As well, increased access to fish habitat may lead to increased fishing

pressure on local fish stocks; however the local area (with the exception of Bear River) is not

believed to be heavily used by Nisga’a and recreational anglers.

Although downstream changes to water and sediment quality are expected to be minimal,

changes in the quality of these features downstream of the Project and potential implications to

fish and fish habitat as well as lower trophic levels will be assessed. Linear features (e.g., power

line and access road rights-of-way) will also be evaluated in the assessment. Mitigation

measures will be implemented to manage any potential effects on fish and fish habitat as

required.

4.2.3 Birds

The potential effects of the Project to migratory birds may include direct mortality from collisions

with power lines, buildings, or vehicles; removal or disruption of nests; loss of habitat due to

vegetation clearing; interference from Project lighting and noise; and effects to health from the

possible degradation of air and water quality. Tree clearing will be limited to the right-of-ways for

the access road and power line. Tree and land clearing will be conducted within the appropriate

timing windows for breeding birds or nest surveys will be completed prior to any construction to

avoid adversely affecting nesting birds. No forest cover clearing will be required at the mine site

as the habitat is high elevation rock and scree and is devoid of tree cover. As a result of the

minimal and limited clearing and proposed mitigation efforts, it is anticipated that there is little

potential for significant effects on bird nesting and habitat in general. Further studies are

underway to determine whether and to what extent migratory birds, as defined in the Migratory

Birds Convention Act, 1994, could be affected. The dominant species present are ptarmigan,

which are not listed in this Act.

4.3 Human Environment

4.3.1 Land and Resource Use

The Project is located in the Bear (Intermediate) landscape unit near the boundary of the

Cambria Ice Field landscape unit (MFLNRO, 2012), and outside areas that have supported

forest activity. The Project is proximal to Old Growth Management Areas 40 and 43, between

Rio Blanco Creek and Hartley Gulch (MFLNRO, 2012).

The Project is not anticipated to require a change in land use other than the use of the area at

the mine site under provincial permits. This land use is proposed to be short-term: based on

known resources, the Project will operate for five years with the possibility of an additional two

years, followed by mine closure, decommissioning of facilities, and reclamation of the land to as

near to its present state as possible.

Improved access during the period of Project construction and operation could affect land and

resource use due to an increase in prospective users of the area.



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4.3.2 Aboriginal Land Use

Potential adverse effects of the Project that may affect Aboriginal and Treaty land use could

include, but are not limited to, impacts on traditional harvesting and cultural activities as a result

of increased human presence and sensory disturbances associated with two years of

construction and five years of operation activities, and changes in access to the Project area.

4.3.3 Viewscapes

The Project will add surface facilities that will be visible only within parts of the Bitter Creek

Valley in close proximity to the facilities. The Project will not be visible from Stewart or Highway

37A.

Upon closure, the removal of structures and rehabilitation of the disturbed ground will reduce

the effect on the viewscape substantially.

4.3.4 Economics

IDM will ensure that the Project provides lasting benefits to local communities while generating

substantial economic and social advantages for shareholders, employees, and the broader

community.

The Project is expected to provide economic benefits to the local non-Aboriginal, Aboriginal,

Métis, and Nisga’a communities as a result of direct training and employment opportunities, as

well as employment and business opportunities. IDM expects to provide full time and seasonal

employment for up 105 person-years during the two-year construction phase of the Project.

During the six-year mine operational phase, permanent and seasonal employment of up to 396

person-years is expected.

The overall economic impacts to the District of Stewart, which is approximately 28 km from the

proposed mine site, nearby communities, and the province are expected to be beneficial. The

larger and more distant communities of Terrace and Smithers have adequate facilities and

infrastructure to absorb potential impacts of Project development, particularly as these are

expected to revolve around company and employee purchases of goods and services. Stewart

is likely to experience the most direct economic impacts from Project development as a result of

the expected increase in employee and company expenditures.

Indirect employment opportunities for goods and services providers will also increase, creating positive spin-off effects in the local, regional, and provincial economies. The Project will also generate annual revenues in the form of property taxes, licensing fees, royalties, and income taxes for local, provincial, and federal governments.

The following tables indicate the estimated labour and processing requirements and economic

impacts for the Project.



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Table 17: Mine Labour Salaries

Position Base Pay Loaded Pay

Rate

MINING LABOUR (QUANTITIES)

Mining Operations

Mine Super/Mine GF Salary $200,000 $247,636

Mine Supervisor/Shift Boss Hourly $32.00 $77.47

Safety / Mine Rescue / Training Officer Hourly $25.50 $58.55

LH Drillers/Blasters Hourly $25.50 $58.55

Ground Support, Hanging Services Hourly $28.70 $67.94

Fuel/Lube/Boom/Grader/Telehandler Hourly $22.35 $44.02

Jumbo & LHD Operator Hourly $31.00 $71.10

Truck Operator Hourly $28.70 $67.94

Backfill

Backfill Crew - Bulkheads, Piping, Monitor Hourly $22.35 $44.02

CRF Plant Operators Hourly $25.50 $38.55

Mining Maintenance

Mine Maintenance Supervisor/Lead Hand Hourly $32.00 $77.47

Maintenance Planner Salary $110,000 $141,436

HD Mechanic Hourly $45.00 $89.90

Welder Hourly $28.70 $67.94

Electrician Hourly $45.00 $89.90

Mining Technical Services

Chief Mine Engineer/Sr. Mine Engineer Salary $170,000 $212,236

Mine Planning Engineer Salary $120,000 $153,236

Surveyor Salary $90,000 $117,836

Mine Technologist Salary $90,000 $117,836

Senior Geologist Salary $110,000 $141,436

Grade Control Geologist Salary $80,000 $106,036

Source: JDS (2014)



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Table 18: Processing Labour Requirements & Costs

Process Labour Salary/Hourly Base Pay Loaded Pay Quantity

Milling Operations

Mill General Foreman Salary $150,000 $188,636 2

Mill Shift Supervisor Hourly $40 $58 4

Mill Operators Hourly $32.00 $47.47 12

Milling Operations - Total 18

Met Lab & Quality Control

Plant Metallurgist Salary $130,000 $165,036 2

Assay Technicians Hourly $40.00 $58.45 2

Metallurgical Technician Staff $90,000 $117,836 2

Met Lab & Quality Control - Total 6

Plant Maintenance

Mill Maintenance Shift Foreman Salary $150,000 $188,636 2

Maintenance Planner Hourly $45.00 $64.90 2

Millwrights Hourly $45.00 $64.90 2

Instrument Technicians Hourly $45.00 $64.90 2

Plant Maintenance - Total 8

Total Process Labour 32

Source: JDS (2014)



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Table 19: G&A Labour Requirements & Costs

G&A Labour Salary/Hourly Base Pay Loaded Pay Quantity

General Manager Salary $230,000 $283,036 1

General Manager - Cross Shift Salary $184,000 $228,756 1

Administration Salary $70,000 $93,882 2

Purchaser Salary $100,000 $129,636 2

Environment Manager Salary $120,000 $153,236 2

Environment Technician Salary $80,000 $106,036 2

Clerk - Shared Salary $50,000 $68,768 2

Site Services Hourly $45.00 $74.90 8

Warehouse men Salary $50,000 $68,768 2

Bus Drivers Hourly $28.70 $43 2

Total G&A Labour 24

Source: JDS (2014)

4.3.5 Socio-Community

The workforce for the construction, operations, and decommissioning phases of the Project is

expected to be based in Stewart, which has sufficient facilities and infrastructure to

accommodate the potential increase in residents. Services in Stewart provided by government

agencies, communication and media outlets, commercial operations, and transportation

industries would continue to adequately serve the increased population. Power, water supply,

solid waste management services, and community services and infrastructure currently

available in Stewart are adequate to provide for the population increase associated with the

Project. Stewart is served by elementary and secondary schools, both of which are operating

below capacity.

4.3.6 Human Health

The Project is not anticipated to adversely affect human health in or proximal to the Project

area. Air emissions are expected to be small, involving hydrocarbon and particulate emissions

primarily from vehicles and equipment use and the mill. The nearest community (Stewart) to the

area is separated from the Project area by a mountain range. Air emissions will be limited to

approximately 9 months of the year, with no emissions during the coldest months due to

shutdown.

Use of traditional resources and country foods in the Bitter Creek and lower Bear River Valleys

which could be affected by changes in the air quality or water quality during construction and

operation of the Project. These potential Project impacts will be assessed through consultation

with NLG and the review of available information.



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4.3.7 Archaeological and Heritage Resources

Although no archaeological or heritage sites have been recorded in the Project area, IDM will

undertake an Archaeological Overview Assessment and, if necessary, an Archaeological Impact

Assessment to confirm whether or not any archaeological or heritage values are present and

likely to be affected by the Project.

Further, IDM will work with NLG, with respect to NFA Chapter 10, section 8(f), and the collection

of Traditional Knowledge and Use information to further identify Treaty and Aboriginal interests

in the Project area and potential adverse effects on interests. Mitigation measures will be

developed in consultation with NLG throughout the EA process.

4.3.8 Aboriginal, Commercial, and Recreational Fishery and Fishing Areas

In conjunction with the assessment of fish and fish habitat (see section 4.2.2) the Project may

affect Aboriginal, commercial, and recreational fisheries. Though significant impacts are not

expected, the potential for loss of productivity and the fishery will be assessed.

IDM will work with NLG, with respect to NFA Chapter 10, section 8(f), and the collection of

Traditional Knowledge to further identify Treaty rights and interests related to fisheries in the

Project area and potential adverse effects on fisheries. Mitigation measures will be developed in

consultation with NLG through the EA process.

IDM will also engage and consult with Skii km Lax Ha and MNBC to identify Aboriginal rights

and interests in the Project area, and any potential impacts to those Aboriginal rights and

interests, as directed by the provincial and federal governments.



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5 CONSULTATION

IDM will continue to seek meaningful and respectful engagement with the Nisga’a Nation, as

represented by NLG, the public, and agencies throughout the Project’s planning and regulatory

review, construction, and operational phases. IDM’s engagement and consultation process is

structured to ensure meaningful and comprehensive consultation that will meet the needs of

NLG as well as regulators, the public, and other potentially affected stakeholders. The

engagement and consultation process will include in-person meetings, sharing of Project

information (including potential Project effects and potential mitigations measures to minimize or

avoid those potential adverse effects of the proposed Project), participation in Working Group

meetings, and tracking and responding to issues raised during consultation. IDM will prepare an

Aboriginal Consultation Plan outlining the proposed engagement and consultation activities for

review and comment by NLG and regulators as part of the provincial EA process.

To date, IDM has been directed to consult only with Nisga’a, as represented by NLG. IDM will

initiate engagement and consultation activities with other Aboriginal Groups if directed to do so

by regulators.

5.1 Aboriginal Groups

5.1.1 Nisga’a Nation

The Project falls within the Nass Wildlife Area as set out in the NFA. Pursuant to the NFA,

Nisga’a has Treaty rights to the management and harvesting of fish and wildlife within the Nass

Wildlife Area.

Additionally, Sgamagunt, formerly Scamakounst Indian Reserve 19, is the nearest parcel of

Category A Land, as defined in the NFA, and is held by Nisga’a as estate in fee simple.

Sgamagunt is situated on the east bank of the Bear River, approximately 500 m across from

Stewart, BC. Waters draining from Red Mountain flow into Bitter Creek, which in turn flows into

the Bear River upstream of Sgamagunt.

IDM has initiated early engagement with NLG, who has expressed the willingness to discuss the

idea of a mining operation within the Nass Wildlife Area, provided the mining operation is

developed and operated in an environmentally responsible manner that is mutually beneficial for

both IDM and NLG. Engagement activities to date include the provision of initial Project

information materials, a face-to-face meeting with NLG executives, information-sharing with the

NLG Lands and Resources staff, and, a meeting to discuss the potential valued components

(VCs) for the Project. The primary contacts at NLG have been Collier Azak, Chief Executive

Officer, Mansell Griffin, Lands Manager, and Tracey McKay, Senior Lands Officer, at the Lands

and Resources Department.



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Figure 5: Regional Aboriginal Community Boundaries



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5.1.2 Engagement and Consultation Activities to Date

To date, IDM initiated and conducted engagement and consultation activities with Nisga’a, as

represented by NLG. No engagement or consultation activities have been conducted or initiated

with other Aboriginal Groups.

IDM initiated engagement with NLG on May 26, 2014, with a letter introducing IDM and the

proposed Project. NLG responded with a letter to IDM on June 4, 2014, and proposed the

conditions of meeting to discuss the proposed Project. The conditions were acceptable to IDM

and an initial meeting was held July 21, 2014.

Throughout the summer of 2014, IDM kept NLG up to date on the progress of investigative

permits, environmental baseline field studies, and the commencement of investigative works at

the site. Nisga’a citizens were employed by IDM as part of the environmental baseline field

studies and investigative works.

On September 12, 2014, IDM provided NLG with a draft copy of the Project Description and

invited NLG to provide comments on that document. NLG provided IDM with comments on the

document on October 22, 2014; these comments have been taken into consideration and

incorporated into the final Project Description where appropriate.

On November 7, 2014, IDM and NLG held a meeting to discuss the proposed Project and

potential valued components (VCs). Table 20 lists the comments and concerns expressed by

NLG at that meeting.

More recently, IDM senior management sent correspondence to the NLG advising them of the

status of activities at the Project site and plans for field studies in 2015.

The following table summarizes the NLG comments and concerns received by IDM during these

early engagement activities.

Table 20: NLG Comments and Concerns

NLG Comment or Concern IDM Response

NLG raised concerns about why the proposed access road was not scoped into the Project Description. Specifically, they raised concern about the lack of robust baseline and consultation activities required in a Notice of Work process compared to those required during the EA process.

In response to concerns raised by NLG and other regulatory agencies, IDM has decided to include the access road in the scope of the EA.

NLG would like to have biologists present during the investigative fieldwork associated with the access road layout.

IDM will include NLG’s biologists in the planning of the investigative fieldwork associated with the access road layout.

NLG wishes to maintain an ecosystem network to connect the high-value habitat and the ecosystem of the Bitter Creek network.

IDM will take this into consideration when planning the layout of the Project.



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NLG Comment or Concern IDM Response

NLG suggested conducting vegetation surveys, as there had been a new species of plant discovered at a nearby project.

IDM has conducted floristic surveys and dedicated rare plant surveys at the mine site and other areas within Bitter Creek, including sites along the proposed road, as part of the terrestrial ecosystem mapping.

A Nisga’a Economic, Social, and Cultural Impact Assessment is required to be completed; a scope of work needs to be developed with input from NLG. NLG has provided IDM with guidelines.

IDM will work with NLG to develop the scope of work and conduct the Nisga’a Economic, Social, and Cultural Impact Assessment, as per the guidelines, in 2015.

NLG expressed that they would like the local study area (LSA) to include the lower Bear River in addition to Bitter Creek.

The LSA has been expanded to include the lower Bear River.

NLG requested to be able to provide input on the environmental baseline studies. NLG also suggested reviewing the Kitsault and Brucejack EA applications to ensure NLG’s VCs are included.

IDM will continue to consult with NLG on the environmental baseline studies in 2015. IDM has also been reviewing the Kitsault and Brucejack EA applications for the relevant VCs, including eulachon and grizzly bears.

NLG requested the following VCs:

Marten

Wolverine

Hoary marmot

Western toad

Tail frogs

Cottonwood trees

Eulachon

Grizzly bears

Moose

IDM will include these in the VC Selection Document.

NLG requested more information regarding metal leaching and acid rock drainage

In 2015, IDM will arrange a follow-up meeting between NLG, their biologists, and IDM’s geochemistry consultant to response to NLG’s questions.

For Nisga’a employment opportunities, NLG suggested IDM contact the Native Development Society, Lisims Forest Resources (LFR), and Nass Area Enterprises.

IDM will follow-up with these contacts in 2015 when planning field work.

NLG requested that a draft VC Selection Document be provided to them for review and comment.

IDM will provide the draft VC Selection Document to NLG for review and comment in 2015.

The following table provides a summary of the engagement and consultation activities

conducted to date:



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Table 21: Summary of Engagement and Consultation Activities to Date

Date Aboriginal

Group Communication

Method Description

May 26, 2014 Nisga'a Lisims Government

Letter (via email) IDM emailed a letter to the Nisga'a Lisims Government (NLG) to introduce IDM Mining (IDM) and the Red Mountain Gold Mine Project. The letter included an offer to meet in New Aiyansh to discuss the Project.

June 4, 2014 Nisga'a Lisims Government

Letter (via email) NLG emailed a letter to IDM outlining the Nisga'a Nation's land management under the Final Agreement and conditionally accepting IDM's offer to meet to discuss the Project.

July 3, 2014 Nisga'a Lisims Government

Letter (via email) IDM emailed a letter to NLG providing an update on the Project's timeline through the environmental assessment process and to say that IDM look forward to meeting with NLG at their earliest possible convenience.


Telephone IDM and NLG had a telephone conversation to clarify that the Project does not fall within Category B Lands, as IDM had stated in previous correspondence. The Project still falls within the Nass Wildlife Area.

NLG asked IDM to confirm that they were no longer considering using Kitsault Lake for the tailings pond. IDM confirmed and stated that the location of the tailings pond has not yet been determined.


Email IDM provided a map of the Project, showing its location relative to the Category B Lands, the Nass Wildlife Area, and the NLG commercial recreation licences.


Letter (via email) IDM emailed a letter to NLG to confirm the location of the Project relative to Nisga'a lands.


Meeting IDM and NLG met to discuss the Project. IDM provided an overview of IDM and the Project. NLG provided an overview of the NLG structure, the treaty, and the Nass Wildlife Area.

IDM committed to ensuring continuous dialogue with NLG as the Project progresses.


Email IDM provided the Preliminary Economic Assessment (PEA) for the Project with an invitation to discuss it.



Page 59 of 76

Date Aboriginal

Group Communication

Method Description


Telephone IDM called NLG to discuss upcoming environmental baseline field studies: aquatics surveys, fishery surveys, and terrain hazard surveys.

IDM asked if any NLG members were registered biologists who were available to conduct the studies. NLG responded that they would check their membership database.

IDM also asked NLG if they have a preferred consultant to conduct the Archaeological Overview Assessment.

IDM followed-up on this conversation with an email.


Telephone IDM called NLG to confirm the employment of two field assistants for the upcoming field environmental studies.


Email IDM confirmed the employment of a Nisga'a member in the upcoming environmental field studies.

August 21, 2014 Nisga'a Lisims Government

Email In response to IDM's request, NLG provided the shapefiles for the Nass Area, the Nass Wildlife Area, and Nisga'a Lands in support of IDM's draft Project Description.


Email IDM provided NLG with an amended Notice of Work (NoW) package which included the amended claim outlined, amended NoW area, areas of proposed drilling, and shapefiles for the amended areas.

IDM also provided the finalized Goat Management Plan that had been prepared for the work.


Email IDM provided NLG with a memo on underground water quality results for the Project and recommendations from a qualified professional for the development of an underground water quality monitoring plan.

September 10, 2014 Nisga'a Lisims Government

Email IDM notified NLG that the NoW had been issued and that work was commencing on site.


Email IDM provided a press release to NLG regarding the issuance of the NoW and the commencement of work on site.



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Date Aboriginal

Group Communication

Method Description


Letter (via email) IDM emailed a letter to NLG with a draft version of the Project Description. IDM invited NLG to meet to discuss the document.


Telephone IDM spoke to NLG to clarify who would be the best contact to receive the Wildlife Observation Logs.


Email IDM provided a copy of the Wildlife Observation Logs to NLG.


Email IDM provided NLG with an update on the employment of Nisga'a members at the Project site.


Email NLG provided feedback to IDM on the Wildlife Observation Logs. NLG requested that a registered professional biologist review the logs for quality control and quality assurance.


Telephone NLG and IDM discussed NLG's feedback on the Wildlife Observation Logs. NLG provided a clarification of what changes they would like to see to the logs.


Email IDM provided NLG with an update on the employment of Nisga'a members at the Project site.

October 1, 2014 Nisga'a Lisims Government

Email IDM provided NLG with an updated Wildlife Observation Log. As per NLG's request, a registered professional biologist, reviewed the logs and provided quality assurance of the data.


Telephone IDM followed-up with NLG to see if there were any comments on the draft Project Description which was provided to NLG on October 1.


Email IDM followed-up with NLG to see if there were any comments on the draft Project Description which was provided to NLG on October 1.


Email IDM emailed NLG to offer to hold an Issue Scoping and Valued Components Selection Workshop in New Aiyansh.



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Date Aboriginal

Group Communication

Method Description


Email IDM followed-up with NLG to see if there were any comments on the draft Project Description which was provided to NLG on October 1. IDM wrote that they would like to submit the document on October 24 and asked for any comments to be submitted by October 22.


Telephone IDM and NLG discussed the draft Project Description. NLG notified IDM that they had not yet compiled all of their internal review panel's comments and might not be able to do so by October 22. NLG asked to see the comments made by the EAO on the draft document.

IDM and NLG also discussed the proposed Issues Scoping and Valued Components Selection Workshop. It was agreed to hold the workshop in Vancouver on November 7.

October 22, 2014 Nisga’a Lisims Government

Letter (via email) NLG provided comments on the draft Project Description.

November 7, 2014 Nisga’a Lisims Government

Meeting IDM and NLG met to discuss the Project and potential valued components (VCs). NLG provided direction to IDM for VC selection and planning for fieldwork and environmental baseline studies.

November 13, 2014 Nisga’a Lisims Government

Email IDM provided a press release to NLG regarding the results of the diamond drilling program.

December 2, 20214 Nisga’a Lisims Government

Email IDM provided a press release to NLG regarding the results of the exploratory drilling program.

December 15, 2014 Nisga’a Lisims Government

Telephone IDM and NLG discussed the scheduling of a meeting with IDM’s geochemistry consultant (in follow-up to the November 7, 2014, meeting) in 2015.

IDM and NLG also discussed the potential archaeologist IDM was considering engaging to perform the Archaeological Overview Assessment. NLG had no concerns regarding the suggested archaeologist and requested the IDM confirm the archaeologist once the contract had been finalized.

January 14, 2015 Nisga’a Lisims Government

Email IDM provided a press release to NLG regarding the results of sampling from drill cores.



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Date Aboriginal

Group Communication

Method Description

July 6, 2015 Nisga’a Lisims Government

Letter IDM sent a letter to NLG executive on current status of the Project and near term plans for field studies and permitting. The letter was acknowledged by e-mail from an NLG representative and a meeting between NLG and IDM is being set up.

5.1.3 Métis Nation of BC

There are two Métis communities in general proximately to the Project: the Northwest and Tri

River Métis Associations of BC. The total Métis population in the Regional Districts of Kitimat-

Stikine and Buckley-Nechako, electoral district A combined is approximately 1,100.

Traditionally, Métis harvest bear, fish, ungulates, small game, and timber products and gather

forest resources. The impact of Project activities on MNBC’s traditional use will be further

determined through the course of the Project’s assessment.

To date, IDM has not conducted or initiated any discussions, engagement, or consultation with

MNBC and, as such, have not received any comments or concerns regarding the proposed

Project.

5.1.4 Skii km Lax Ha

The proposed Project overlaps with the asserted traditional territory of Skii km Lax Ha. Skii km

Lax Ha members actively fish, hunt, trap, camp, and gather plants, berries, and mushrooms on

their traditional territory. These activities are important for sustenance and to supplement

income from the wage economy.

To date, IDM has not conducted or initiated any engagement or consultation with Skii km Lax

Ha and, as such, have not received any comments or concerns regarding the proposed Project.

IDM has notified Skii km Lax Ha of the proposed Project and have provided updates on the

development of the Project through emails and phone calls.

5.1.5 Proposed Future Consultation and Engagement Activities with Nisga’a Nation

IDM will continue to seek meaningful and respectful consultation and engagement with NLG in

2015 and as Project development continues. The goal of these consultation and engagement

activities will be to:

Identify Nisga’a’s Treaty interests in the Project area;

Identify the potential effects of the Project on those Treaty interests, including residual and

cumulative effects;

Comply with all applicable NLG laws, particularly as they relate to the Nass Wildlife Area;



Page 63 of 76

Ensure that the feedback and concerns received from Nisga’a are understood and

considered in Project design and implementation, as appropriate;

Ensure that issues and concerns regarding potential environmental or socio-economic

effects related to the NLG are addressed, as appropriate; and

Engage in discussions regarding effective avoidance, mitigation, and management

measures.

IDM will engage and consult with NLG throughout the EA process to understand potential

effects of the proposed Project on Nisga’a’s Treaty interests, including residual and cumulative

effects. IDM will also work with NLG with respect to conducting a Nisga’a Economic, Social,

and Cultural Impact Assessment to further identify potential Project effects.

Based on preliminary discussions with NLG, as well as a review of established Nisga’a Treaty

rights, Nisga’a’s Treaty interests are likely to include: fisheries resources (both as subsistence

and economic resources), hunting and trapping of terrestrial mammals, and gathering of

traditional use plants for subsistence, economic, and ceremonial purposes. Through

consultation with NLG, IDM hopes to better understand Nisga’a’s Treaty interests in the Project

area and minimize the effects of the Project on those Treaty interests through avoidance,

mitigation, and management measures.

The level of consultation required for the EA will be set by the Order under Section 11 of

BCEAA and will be based on the Province's assessment of Nisga’a’s rights under the NFA

and/or the asserted or proven rights and title of any other potentially affected Aboriginal Groups.

As part of the provincial EA process, IDM will prepare an Aboriginal Consultation Plan that will

outline all proposed consultation activities required to meet the consultation responsibilities

delegated to the Proponent under the Section 11 Order. IDM will ensure that NLG has the

opportunity to review the Aboriginal Consultation Plan prior to its finalization. IDM will conduct

consultation and engagement activities with other Aboriginal Groups if they are included in the

Section 11 Order. IDM acknowledges that additional consultation activities may be required

under Chapter 10 (Environmental Assessment and Protection) of the Nisga’a Final Agreement.

Based on Section 11 Orders issued for other projects in the area, IDM is planning to consult

with NLG on draft versions the following documents:

Aboriginal Consultation Plan;

VC Selection Document;

Draft Application Information Requirements (dAIR);

Application for an Environmental Assessment Certificate; and

Aboriginal Consultation Summary Reports.

In addition to the consultation activities listed above, IDM will propose to conduct engagement

activities with NLG and Nisga’a citizens to build and maintain positive, long-term relationships

and to maximize the benefits of the proposed Project for Nisga’a and its citizens. Engagement

activities might include:



Page 64 of 76

Open houses and forums in the Nisga’a communities to provide information on the Project

and employment opportunities;

Providing Project update information to NLG and Nisga’a citizens;

Including NLG consultants and Nisga’a elders in the design and development of

environmental baseline studies;

Including NLG consultants and Nisga’a field workers in investigative activities, including the

environmental baseline studies; and

Working with NLG to identify contracting and employment opportunities related to the

development, construction, operation, and decommissioning of the Project.

IDM will continue to engage in dialogue with NLG to identify other engagement activities that

NLG feels would benefit its citizens.

5.1.6 Special Consultation Considerations Under the Nisga’a Final Agreement

Pursuant to Chapter 10, section 8, of the NFA, additional consideration will be given to Nisga’a

throughout the EA.

In particular, Chapter 10 of the NFA requires that in addition to applicable environmental

assessment legislation, for projects where there is a potential for significant adverse effects to

occur, the environmental assessment process will:

8(e) assess whether the project can reasonably be expected to have adverse environmental

effects on residents of Nisga’a Lands, Nisga’a Lands, or Nisga’a interests set out in the

Agreement and, where appropriate, make recommendations to prevent or mitigate those

effects; and

8(f) assess the effects of the project on the existing and future economic, social and cultural

well-being of Nisga’a citizens who may be affected by the project.

5.1.7 Proposed Future Consultation and Engagement Activities with Other Aboriginal

Groups

To date, IDM has been directed to consult only with Nisga’a, as represented by NLG. IDM will

initiate engagement and consultation activities with other Aboriginal Groups, such as MNBC

and/or Skii km Lax Ha, if directed to do so by regulators. IDM anticipates that consultation and

engagement activities with MNBC and Skii km Lax Ha would include:

Providing Project information;

Responding to questions and concerns regarding potential impacts to Aboriginal Interests;

Engaging in discussions regarding effective avoidance, mitigation, and management

measures; and

Working to identify contracting and employment opportunities related to the development,

construction, operation, and decommissioning of the Project.



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5.2 Public and Stakeholders

During the pre-Application phase of the Project, it is anticipated that IDM will hold open houses

in Stewart and in Nisga’a communities. IDM will also consult tenure holders in the Project area,

economic development organizations, businesses and contractors (e.g., suppliers and service

providers), and special interest groups (e.g., environmental, labour, social, health, and

recreation groups), as required. Table 22 provides a list of potential stakeholders for the Project.

Communities near the Project area where public consultation outreach activities may occur

during public comment periods will include, but not necessarily be limited to: the Regional

District of Kitimat-Stikine and the District of Stewart.

To date no formal consultation has occurred with the public and stakeholders, however informal

conversations with Stewart community members and local business have occurred and the

Project has been positively received.

Table 22: List of Potential Stakeholders

Potential Stakeholder Interest

District of Stewart Local Government

Community of Gitlaxt’aamiks Local Government

Community of Gitwinksihlkw Local Government

Community of Laxgalts’ap Local Government

Community of Gingolx Local Government

Regional District of Kitimat-Stikine Regional Government

Northern Health Regional Government

Syntaris Power Corp. Holds a waterpower licence in the Project area

Northern Hydro Ltd. Holds a waterpower licence in the Project area

Last Frontier Heliskiing Operates a heliskiing company in the Project area

Chester Benson Holds a trapline in the Project area

Fred (Freddie) Banerd Holds a trapline in the Project area

Robert Milligan Holds a guide outfitter licence in the Project area

As required by the Section 11 Order, IDM will conduct consultation activities with stakeholders

to identify and better understand their interests in the Project area and the potential effects of

the Project on those interests. Consultation will include discussion of potential mitigation,

avoidance, and management measures to minimize potential adverse effects of the Project on

their interests. Consultation activities with stakeholders might include Project information

updates and letters, meetings, and teleconferences. IDM will provide stakeholders with

notification of any Project milestones and public open houses.



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5.3 Agencies

It is anticipated that the BC EAO will establish a Working Group to participate in the pre-

Application phase of the Project. IDM anticipates that members of the Working Group will

include NLG and federal, provincial, and local government representatives. IDM will attend

Working Group meetings, as directed by the BC EAO, to provide information about the Project,

present baseline study work and results, and discuss potential mitigation measures. IDM will

also meet individually with government agencies and local governments as required during the

EA.

Consultation has been initiated with the BC EAO, MEM, MFLNRO, and MoE.



Page 67 of 76

6 SUSTAINABILITY

IDM is committed to proactive inclusion of health, safety, and environmental policies and

practices that protect Aboriginal Groups and Stakeholders, the Project area and its

surroundings, as well as people from accidents and incidents. IDM is committed to protecting

the environment in all aspects of our operations. IDM management, subcontractors, and

employees are collectively responsible to ensure compliance with local, provincial, and federal

government environmental regulations.

IDM believes that all accidents and incidents are preventable. IDM’s goal is to minimize all

accidents and incidents to “Zero Harm”. Active participation at all levels will ensure that this goal

is achieved.

IDM believes a comprehensive Environmental Management Plan is imperative for work in the

Project area during all phases of the Project. Along with the preventative and prescriptive

policies for managing environmental issues or concerns outlined in this section, IDM demands

full training of staff, knowledge of all emergency management plans, and implementation of all

aspects of these plans and policies in order to do “Zero Harm” to the environment and the

people working and living in and around the Project. IDM recognizes the need to maintain

appropriate environmental quality on any project. IDM fully understands that there is a

considerable amount of scrutiny shouldered by ourselves in regards to regulatory requirements.

IDM strives to ensure that work activities will not be hampered by environmental and human

health incidences due to poor planning.

IDM will maintain high environmental standards consistent with the technology available. IDM

will take an active and aggressive role in minimizing the impact of its operations on the

environment, and will utilize the appropriate technology necessary to minimize environmental

impacts. IDM understands the unique challenges associated with operating a mine in the

current regulatory environment, and will institute a very procedural and recordable program to

ensure that (a) environmental incidences are prevented, and (b) if they do occur, corrective

action is implemented quickly and effectively.

IDM mine closure services will plan the Project from preliminary design to operations with the

final closure design in mind. IDM starts with mineral project evaluation and mine design,

followed by operations. When the life-of-mine ends, the site is restored to conditions that allow

the site to be reused or refitted for another purpose.



Page 68 of 76

7 ENVIRONMENTAL APPROVALS AND PERMITTING PROCESS

7.1 Provincial Involvement, Approvals and Permitting

Provincial permitting and licensing is expected to proceed concurrently with the environmental

review pursuant to BCEAA. Consequently, IDM will apply for concurrent permitting within the

environmental review process for all provincial permits. It is anticipated that all provincial permit

applications for the Project will be coordinated through the Major Projects Office of MFLNRO.

Table 23 presents the principal provincial authorizations, licences, and permits anticipated for

the construction and operation of the Project. The list is not intended to be comprehensive and

as the environmental review continues, the need for other authorizations, licenses, or permits

will be determined.

Table 23: List of Anticipated Provincial Permits and Authorizations

Permits Agency Legislation

Environmental Assessment

Certificate BC Environmental

Assessment Office

Government of BC, Environmental

Assessment Act

Licence of Occupation Ministry of Forests, Lands and

Natural Resource Operations

Government of BC, Land Act

Licence to Cut Ministry of Forests, Lands and


Government of BC, Forestry Act

Road Use Permit Ministry of Forests, Lands and


Government of BC, Forestry Act

S.14 Inspection Permit Ministry of Forests, Lands and


Government of BC, Heritage

Conservation Act

S.12 Site Alteration Permit Ministry of Forests, Lands and


Government of BC, Heritage

Conservation Act

Burning Reference Number Ministry of Forests, Lands and


Government of BC, Wildfire Act

S.9 Approval or Authorization

for Changes In and About a

Stream

Ministry of Forests, Lands and


Government of BC, Water Act

S.8 Authorization for Short

Term Use of Water Ministry of Forests, Lands and


Government of BC, Water Act

Mining Lease Ministry of Energy and Mines Government of BC, Mineral Tenure

Act



Page 69 of 76


Mines Act permit Ministry of Energy and Mines Government of BC, Mines Act

Mining Right of Way Permit Ministry of Energy and Mines Government of BC, Mining Right of

Way Act

Permit to operate a Food

Premise Northern Health Authority Government of BC, Public Health

Act-Food Premises Regulation and

DWP Act

General Application for Health

Approval Northern Health Authority Government of BC, Public Health

Act- Sewage Disposal Regulation

Water System Operating Permit Northern Health Authority Government of BC, Drinking Water

Protection Act and Regulation

Highway Access

Permit/Provincial Public

Highway Permit Application

Ministry of Transportation and

Infrastructure

Government of BC, Transportation

Act, Motor Vehicle Act

Utility Permit Ministry of Transportation and

Infrastructure

Government of BC, Transportation

Act, Motor Vehicle Act

Hazardous Waste Registration Ministry of Environment Government of BC, Environmental

Management Act- Hazardous

Waste Regulation

Fuel Storage Permit Ministry of Environment Government of BC, Environmental

Management Act

Effluent Discharge Permit Ministry of Environment Government of BC, Environmental

Management Act

7.2 Federal Involvement, Approvals, and Authorizations

The Project exceeds the minimum daily ore production threshold of 600 t/day identified in

section 16 of the Schedule of the Regulations Designating Physical Activities of CEAA 2012.

The Project is therefore expected to require a decision pursuant to CEAA 2012.

No federal financial support is required or involved in the Project.

No federal lands are required or involved in the Project. Table 24 summarizes the distances

from the proposed Project to the nearest federal lands.



Page 70 of 76

Table 24: Proximity to Federal Lands

Federal Land Description Approximate Distance from Proposed

Project

Gwaii Haanas National Park Reserve 380 km

Canadian Forces Base Comox 800 km

Qualicum National Wildlife Area 850 km

The lands on which the Project will be developed are located in the Nass Wildlife Area as set

out in the NFA, and described in section 3.3.2 herein.

A list of anticipated federal permits and authorizations is shown in

Table 25. These will be addressed through the appropriate government agencies.

Information currently available indicates that fish and fish habitat, as defined in the Fisheries Act

will not be affected by the Project.

The Project is not expected to affect marine plants, as defined in the Fisheries Act.

While the potential for significant effects on migratory birds is not expected (based on available

information and limited clearing required), further studies are underway to determine whether

and to what extent migratory birds, as defined in the Migratory Birds Convention Act, 1994,

could be affected. The dominant species present are ptarmigan, which are not listed in this Act.

Table 25: List of Anticipated Federal Permits and Authorizations


Explosives Permit NRCan Government of Canada,

Explosives Act

Decision pursuant to CEAA 2012 Canadian Environmental

Assessment Agency CEAA 2012

7.2.1 Potential Trans-boundary Impacts

Based on historical data, the proposed design of the Project, and the current information being

collected as part of baseline environmental programs (in particular, climatic and hydrological

data), significant environmental impacts beyond or within the Canadian border are not

anticipated as a result of the construction, operations, and the future decommissioning of the

Project.



Page 71 of 76

The Project is located approximately 20 km from the Canada-USA border in a straight line and

within the Bear River drainage catchment area in northwestern BC. Surface water from the mine

will flow into Bitter Creek and then in turn into the Bear River. Water from the Bear River will

flow into the Canadian end of the Portland Canal, just south of Stewart, BC. Downstream

drainage from the Project will travel approximately 38 kilometers before entering the Canadian

waters of the Portalnd Canal. Figures 6 and 7 illustrate the location of the Bear River drainage

area in relation to the international boundary with Alaska, USA.

Surface water flow from the Project is not anticipated to be a significant portion of Bitter Creek;

therefore, significant environmental impacts beyond or within the Canadian border are not

anticipated. During the course of the EA, IDM intends to provide further data to support this

assertion.

Moreover, significant impacts to economic, social, heritage, or health values are not anticipated

beyond the Canadian border as no transportation, infrastructure, or service activities related to

the Project will be conducted outside of BC.



Page 72 of 76

Figure 6: Catchment Boundaries and Drainages



Page 73 of 76

Figure 7: Catchment Boundaries Drainages Regional View



Page 74 of 76

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2014a. First Nation Profile: Nisga'a Village of Gingolx. Accessed August 2014 at:

http://pse5-esd5.ainc-


http://pse5-esd5.ainc-inac.gc.ca/fnp/Main/Search/FNMain.aspx?BAND_NUMBER=671&lang=eng

http://pse5-esd5.ainc-inac.gc.ca/fnp/Main/Search/FNMain.aspx?BAND_NUMBER=671&lang=eng

APPENDIX A

Photos of Red Mountain Gold Mine

Project



Page 1 of 6

Photo 1: Red Mountain

Photo 2: Exploration Camp at the Red Mountain Project Site



Page 2 of 6

Photo 3: Access Portal to the Red Mountain Underground Mine

Photo 4: Underground Mining Equipment on Red Mountain Near the Access Portal



Page 3 of 6

Photo 5: View of Proposed Road Route alongside Roosevelt Creek, 9km Northwest of Red Mountain Looking North



Page 4 of 6

Photo 6: Proposed Access Road Route Looking Towards Red Mountain



Page 5 of 6

Photo 7: Proposed Access Road Route Looking Southwest Towards Stewart



Page 6 of 6

Photo 8: Glacier Immediately South of the Red Mountain Site

red mountain gold mine

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