TECHNICAL REVIEW COMMENTS on the Environmental Impact Statement

Elizabeth Falls Hydro Limited Partnership and Saskatchewan Power Corporation -

Tazi Twé Hydroelectric Project

Prepared by Saskatchewan Ministry of Environment Environmental Assessment and Stewardship Branch December 2016

TABLE OF CONTENTS Acronyms………………………………………………………....………………………………… ii Preface………………………………………………………….....……………………………….… iii Environmental Assessment and Review Process……..………………………..…. 1

Introduction……………………………………………………………………….… 1 Submission of the Environmental Impact Statement…………... 2 Technical Review…………………………………………...……………….…… 2 Public Review…………………………………………………………………….... 3 Ministerial Decision………………………………………………….............. 3

Summary of Proposed Project…………………………….……………………………….. 3

Alternatives Considered………………………………….....……………….. 4

Technical Review Comments……………………………...……………………………….. 5 Introduction……………………………………………….………………………... 5 Public, First Nations and Metis Engagement Feedback and Response…………………………..……………….…………………………. 5 Biophysical Impacts…………………………………………………………...... 6

Terrestrial Environment…………..………………..…………......... 7 Water and Aquatic Environment …….…………......….……….. 9 Atmospheric and Acoustic Environment…………....….……... 12 Residual and Cumulative Effects…...……….……....…….…….. 13 Effects of the Environment………………………......………………. 14

Heritage and Socio-Economic Considerations……………...………. 14 Heritage Resources……………………………….....…………………… 14 Cultural Considerations…………………………….…………………... 15 Socio-Economic Considerations ……………………………..…….. 15

Decommissioning, Reclamation and Abandonment Plan…….. 16

Conclusions………………………………………………………………………………..……..… 17 Invitation to comment………………………………….……………………… 17 Contact………………………………………………………………………………… 18

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Acronyms BLFN Black Lake First Nation

CEAA Canadian Environmental Assessment Agency

COSEWIC Committee on the Status of Endangered Wildlife in Canada

DTC Crown’s Duty to Consult

EASB Environmental Assessment and Stewardship Branch

EFHLP Elizabeth Falls Hydro Limited Partnership

EIA Environmental Impact Assessment

EIS Environmental Impact Statement

the Act The Environmental Assessment Act (Saskatchewan)

FNCIDA Federal First Nation Commercial Industry Development Act

the Minister Saskatchewan Minister of the Environment

the ministry Saskatchewan Ministry of Environment

the Project Tazi Twé Hydroelectric Project

proponent Elizabeth Falls Hydro Limited Partnership and SaskPower

SARA Species at Risk Act

SaskPower Saskatchewan Power Corporation

SEARP Saskatchewan Environmental Assessment Review Panel (technical reviewers)

TOR Terms of Reference

TRC Technical Review Comments

VC Valued Components

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Preface This document is provided by the Environmental Assessment and Stewardship Branch (EASB) of the Saskatchewan Ministry of Environment (the ministry) as supporting information for the public review of the Black Lake First Nation (BLFN) and Saskatchewan Power Corporation (SaskPower, the proponent) environmental impact statement (EIS) for the proposed Tazi Twé Hydroelectric Project (the Project). BLFN’s interest in the Project is being held through their development arm, Elizabeth Falls Hydro Limited Partnership (EFHLP). The proponent is proposing a 50 megawatt (MW) water diversion-type electrical generating station located on the Black Lake First Nation – Chicken Indian Reserve #224, adjacent to the Fond du Lac River and approximately 25 km west of the northern hamlet of Stony Rapids. Water from Black Lake will be diverted through a water intake structure and power tunnel to the powerhouse before being released into the Fond du Lac River upstream of Middle Lake. The purpose of the Project is to help meet the growing industrial and residential demands on the far north electrical transmission and generation system. The anticipated life of the Project is approximately 100 years. The Project is subject to an environmental impact assessment under The Environmental Assessment Act (Saskatchewan). This document has four major sections: The first section provides an overview of the provincial environmental assessment and review process. It outlines the events and activities that led to the EIS being released for public review and describes how the public can provide comments to the Minister of Environment (the Minister) on the proposed Project. The second section provides a brief summary of the Project. This summary is intended to provide information to assist the reader in deciding whether they are interested in finding out more about the Project. It is not intended to be a full representation of the Project. Interested readers should visit a review centre to read the EIS for the Project (locations are listed in Section 4). The third section of the document provides the ministry’s evaluation of the proponent’s conclusions regarding the predicted impacts of the proposed Project, the effectiveness of any identified mitigative measures and any follow-up requirements that would be placed on the proponent by the Minister, should the Project be approved. The fourth section presents the conclusions reached by the ministry and invites the public to comment. The Minister, when making the final decision regarding the environmental acceptability of the proposed Project, considers both the public’s comments and Technical Review Comments (TRC).

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1. Environmental Assessment and Review Process Introduction The Environmental Assessment Act (the Act) in Saskatchewan requires the proponent of a project that has been deemed a “development” pursuant to section 2(d) of the Act to conduct an Environmental Impact Assessment (EIA). The EIA provides information needed by the Minister responsible for the Act to determine whether, from an environmental perspective, a proposed project should be allowed to proceed and, if so, under what conditions. As part of the environmental assessment process, a proponent is required to prepare an EIS that documents the assessment and conclusions on the potential environmental effects of a proposed project. The EIS also describes the measures a proponent plans to take to reduce negative effects and enhance positive environmental impacts. Once completed, the EIS undergoes both a technical and public review prior to a decision being made by the Minister regarding the project. The purpose of the environmental assessment and review process is to ensure that adequate environmental safeguards are in place before a development is allowed to proceed and that it proceeds in a manner understood and broadly accepted by the public. These safeguards may arise out of the actual design and nature of the proposed project or, should the project receive approval under the Act, as a result of ongoing regulatory involvement by government agencies. In addition to the Act, this Project may be subject to other provincial and federal Acts and regulations. In December 2015, the provincial and federal governments and Black Lake First Nation began formal negotiations in order to establish a Tripartite Agreement and draft First Nation Commercial Industrial Development Act (FNCIDA) Regulations. The intent of the FNCIDA Regulations is to ensure that certain provincial laws apply as federal law to the project, within the limits of federal constitutional authority, and that the province can effectively regulate project activities on federal lands. Provincial legislation and regulations integrated into the FNCIDA regulations include:

• The Environmental Management and Protection Act, 2010; • The Environmental Management and Protection (Saskatchewan

Environmental Code Adoption) Regulations; • The Hazardous Substances and Waste Dangerous Goods Regulations; • The Water Power Act; • The Water Power Regulations; and, • The Water Security Agency Act.

The EIA review process provides a broad understanding of potential environmental impacts associated with a project and the measures proposed to mitigate their effects.

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Additional provincial legislation including: The Fisheries Act (Saskatchewan), 1994; The Forest Resource Management Act; and The Wildlife Act, 1998 may also apply to address off-reserve impacts. Submission of the Environmental Impact Statement On January 14, 2013 the EASB received a proposal from the proponent for the Tazi Twé Hydroelectric Project. The proposal underwent screening to determine whether or not the Project was a development under the Act which included a technical review by the Saskatchewan Environmental Assessment Review Panel (SEARP). Following technical review of the proposal, the Project was determined to be a development under Section 2(d) of the Act due to potential impacts on fish and wildlife and their habitats in and around Black Lake, Fond du Lac River and Middle Lake. The proponent was advised on February 27, 2013 that the Project is a development and an EIA was required, with findings of the EIA to be detailed in an EIS for submission to the ministry for review. The Canadian Environmental Assessment Agency (the Agency) determined that a federal assessment was also required for the Project. Subsequent to public notification of the EIA in March 2013, the proponent submitted a Terms of Reference (TOR). The TOR outlined specific studies that would be conducted to obtain information on the potential impacts of the Project and documented in the EIS. The TOR was reviewed by SEARP and was accepted as final on August 7, 2013. The EASB concluded that the proposed Project would impact access to areas where First Nations and Métis communities are known to practice traditional uses triggering the Crown’s duty to consult (DTC). Potentially impacted First Nations and Métis communities were notified of the EIA and the DTC requirement on April 10, 2013. The proponent was directed to meet with potentially affected First Nation and Métis communities to inform them about the Project and solicit feedback on the potential impacts on the resources required to hunt, fish and trap for food and carry out traditional land use activities. Technical Review The EIS was received in February 2014 and reviewed by provincial technical reviewers to ensure that potential environmental issues (including biophysical, social and economic) had been identified and adequately addressed. The technical review identified several environmental and technical issues that required revisions and additional clarification before the EIA process could proceed to the public review phase. A revised EIS was subsequently submitted

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and following additional technical review, was judged to contain adequate information to proceed with public review. This TRC document has been prepared pursuant to Section 11 of the Act and is meant to assist the public and government decision-makers in their review by summarizing the information within the EIS. The TRC represent a summary evaluation of the proponent’s EIS. In preparing the TRC, the ministry focuses on those factors that are considered to be of primary significance with respect to the proposed Project and the environment in the Project area. Public Review Pursuant to Section 12 of the Act, both the EIS and TRC are made available for public inspection for a period of not less than 30 days. During the 30 day review period, members of the public may make written submission to the ministry regarding the EIA and information provided in the EIS and associated documents. Interested readers should visit a review centre or the ministry website (saskatchewan.ca/environmentalassessment) to review the EIS for the Project (locations are listed in Section 4). Ministerial Decision Information generated during the public and technical reviews of the EIS will be submitted to the Minister for consideration. The Minister, under Section 15 of the Act, may give ministerial approval to proceed with the development, with any terms and conditions that the Minister considers necessary or advisable, or the Minister may refuse to approve the development as proposed and will provide reasons for the decision. 2. Summary of Proposed Project Information in this section is taken from the Project EIS and is neither comprehensive nor inclusive of the information contained in that document. Please refer to the Executive Summary and the EIS main document, appendices, annexes and addendums for complete information. The Project would be located on the Black Lake First Nation – Chicken Indian Reserve #224, adjacent to the Fond du Lac River between Black Lake and Middle Lake. The proponent is proposing to construct a 50 MW water diversion type generation station which would operate for approximately 100 years.

The public is invited to comment on the Project EIS during the public review period from December 10, 2016 to January 13, 2017.

The Minister considers both the public and technical review comments when making a decision.

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The scope of the Project includes:

• diversion of approximately 190 m3/s, from an annual discharge of 305 m3/s into the Fond du Lac River, to the powerhouse with the remaining water flowing down the Fond du Lac River;

• a water intake located in Black Lake, approximately 2.95 km of tunnel excavated through rock to the powerhouse, and a tailrace (water spillway) extending for approximately 1.1 km from the powerhouse to the Fond du Lac River; and,

• ancillary developments including a construction camp, powerhouse infrastructure, access road, a bridge across the Fond du Lac River connecting the Project site to Highway 905, and a submerged rock weir in the Fond du Lac River at the outlet of Black Lake to maintain water levels and fish habitat in Black Lake.

Water management at the site during construction and operation would ensure protection of water resources by employing a surface water collection system. In addition, all water collected will be analyzed before it is discharged into the Fond du Lac River. Alternatives Considered Alternatives considered for the Project are presented in Section 4.0 of the EIS. This section discusses the consideration of alternatives related to several Project components including: types of electrical facilities (dam and spillway, purchased power, transmission pathway to the north, diesel generation, wind and hydro); water intake, water tunnel and surge facility location; power generation capacity and turbine selection; tailrace channel location; dam vs. submerged weir at the Black Lake outlet; waste rock disposal areas; and others. In determining the preferred alternatives, consideration was given to both the economic, technical and environmental factors. SaskPower opted for a hydroelectric facility with submerged weir over conventional aboveground dam construction, and water supply via tunnel. The Project includes a 50 megawatt water diversion design where water from Black Lake will be diverted through a water intake structure and power tunnel to the power station before being released into the Fond du Lac River upstream of Middle Lake. Additional benefits of the submerged weir at the Black Lake outlet to Fond du Lac River include maintaining water levels in Black Lake during Project operations while facilitating safe downstream passage for all fish species.

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3. Technical Review Comments Introduction The intent of the technical review phase of the environmental assessment and review process is to give provincial subject matter experts from across multiple government agencies and ministries an opportunity to examine the EIS to:

• develop their opinions about how adequately the environmental issues related to the Project have been characterized and addressed; and,

• determine whether the information provided is sufficiently complete and technically accurate enough to support the public review phase of the process.

The technical review of the EIS identified issues related to potential environmental impacts and proposed environmental management that required clarification. These issues were addressed with additional information and the results were presented in the final EIS submission. Upon further review, the final EIS was considered to contain adequate information to proceed with public review. Release of the EIS for public review indicates all significant information requirements in the EIS have been addressed. Any remaining issues identified during technical review could be addressed through regulatory and permitting activities or terms and conditions that may be imposed in a decision made pursuant to the Act, if the Project is approved. In general, the proponent has addressed the significant issues raised during review of the initial EIS submissions. Further refinement of Project technical details would be developed in conjunction with regulators at the time of permitting and licensing should the development receive ministerial approval. Public, First Nations and Métis Engagement Feedback and Response Section 6 and Appendices 6.1 to 6.5 of the EIS provides details on the proponent’s engagement with the public, and First Nation and Métis communities. The proponent initiated engagement activities in June 2010 to provide information about the Project through various media, open houses, site tours, workshops and a webpage. The proponent submitted additional stakeholder engagement records for activities conducted since the submission

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of the EIS in February 2014 which can be found in Addendum III, Attachment M of the EIS. The proponent conducted meetings with First Nation and Métis communities to gather information on the potential of the project to impact Treaty or Aboriginal rights. Concerns raised by First Nation and Métis communities centered around the potential impacts to aquatic habitat or fishery resources used to exercise Treaty and Aboriginal rights and practice traditional uses in lakes and rivers in the project area. Other concerns raised included flooding, water levels and aesthetics of river flows, waste rock storage piles, impacts to a local fishing camp, impacts to water quality, potential impacts of the Project on surrounding communities, noise associated with the Project, impacts to heritage sites and job opportunities. Project specific concerns raised during engagement and consultation activities were addressed by the proponent during meetings and have been documented in the EIS. Further opportunities for participation in the environmental assessment process will be provided during the review period of the EIA. The Crown is committed to fulfilling its duty to consult obligations with potentially affected First Nations and Métis communities as described in the province’s First Nations and Métis Consultation Policy Framework. Consultation activities would also continue as required through the subsequent licensing and permitting phase by the responsible branch/agency, should the Project proceed to that stage. Biophysical Impacts The proponent has evaluated the possible impacts of the Project on the biophysical environment, possible mitigation measures that could be employed to eliminate or mitigate (reduce) the impacts and any residual effects that might remain after mitigation is in place. The environmental assessment methodology used to analyze project-related effects and determine the significance of these effects is described in Section 7 of the EIS. In undertaking the EIS, valued components (VCs) were identified to facilitate the assessment and interpretation of potential effects associated with the proposed Project. These VCs (hydrology, terrestrial habitat, etc.) were chosen, in part, through the proponent’s engagement activities with government officials, the public and First Nation and Métis communities. Within selected VCs are various endpoints (assessed and measured) which identified key properties of VCs requiring protection and quantifiable measures of potential changes associated with the Project. From this information, significant residual impacts of the Project on VCs are predicted. A list of VCs can be found in Section 7 of the EIS.

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Sections 8 to 10, Annexes II to IV, and Addendum II and III of the EIS provide a discussion of various biophysical components of the environment and includes discussions of: the study area considered for each component; baseline information; environmental effects of the Project; residual effects analysis; discussion of uncertainty associated with conclusions; and proposed follow-up and monitoring programs to verify predictions and ensure effectiveness of design features of the Project. Terrestrial Environment The EIS includes discussion of potential impacts of the Project on the terrestrial environment including terrain and soil, vegetation and wildlife. Terrain and Soils The land cover surrounding the Fond du Lac River is primarily bedrock. The Project is situated on a transitional area between the boundaries of two Ecoregions that are separated by the Fond du Lac River; the Athabasca Plain Ecoregion and the Tazin Lake Upland Ecoregion. The Athabasca Plain Ecoregion is on the west side of the Fond du Lac River where landscapes formed on flat-lying sandstone bedrock and sandy glaciofluvial deposits. The Tazin Lake Upland Ecoregion is on the east side of the river where ancient Precambrian (metamorphic) rocks rise more than 100 m above the surrounding terrain. A detailed discussion of soils can be found in Section 13 and Annex IV of the EIS. Waste rock will be produced from excavation of the water intake, power tunnel, powerhouse and tailrace channel. Clean waste rock removed from excavations can be used in other areas of construction with the remaining excavated rock deposited in waste rock disposal areas. Waste rock excavated from the power tunnel will be checked for acid rock drainage and metal leaching potential prior to placement in a permanent waste rock disposal area. A Waste Rock Management Plan can be found in Addendum II, Attachment A of the EIS. A geochemical baseline study is presented in Appendix 9.1 and borehole data is in Addendum II, Attachment R of the EIS. The baseline study found no significant potential for acid generation and no indication of uranium mineralization or the potential for leaching of elevated uranium concentrations from the waste rock. Clearing of the Project site is required for the construction of the water intake, powerhouse, tailrace channel, access road, bridge, construction camp, contractor laydown area, five waste rock disposal areas, and three settling ponds. Site clearing, contouring, and excavation during construction have the

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potential to allow soil erosion to occur. The proponent will develop an erosion and sediment control plan based on industry standard best management practices. A detail Weed Management Plan will also be developed under the Weed Control Act (2010). The draft erosion and sediment control plan and Weed Management Plan is located in Addendum II, Attachment A of the EIS. Section 4.2.2 of the EIS provides information on the proposed 2.95 km long tunnel and surge facility to convey water from Black Lake to the power house. It is anticipated that the tunnel will be constructed using a drill-and-blast method. The surge facility will be incorporated into the Project conveyance system to maintain surge protection to the turbines and regulate tailrace flow to the Fond du Lac River. Vegetation Section 3.8, Section 14 and Annex IV of the EIS includes discussion of potential impacts of the Project on vegetation. No Committee on the Status of Endangered Wildlife in Canada (COSEWIC), Species at Risk Act (SARA), or The Wildlife Act listed plant species were observed during the 2010 and 2012 field surveys. Some vegetation will be directly impacted by the Project but the proponent has committed to minimizing vegetation clearing to the extent possible. Section 14 provides an assessment of the impacts of the Project on wetland vegetation communities. The wetlands occurring on the east side of the Fond du Lac River are small (less than 1-2 hectares) and are largely forested swamps with little free surface water. The proponent has committed to avoiding wetlands wherever possible during Project construction. If infrastructure siting and Project construction cannot be planned to avoid these areas, site-specific pre-disturbance surveys will be completed to determine the area of wetlands potentially affected, the wetland type and appropriate mitigation. Wildlife and Wildlife Habitat Descriptions of wildlife and wildlife habitat are provided in Section 3.8, Section 15, Annex IV and Addendum II, Attachment L of the EIS. Twenty-eight provincially or federally listed species have the potential to occur in the Project area. Four provincially tracked species, Bald eagle (Haliaeeyus leucocephalus), sandhill crane (Grus Canadensis), Tundra swan (Cygnus columbianus) and trumpeter swan (Cygnus buccinators); two COSEWIC species, Horned grebe (Podiceps auritus) and wolverine (Gulo gulo); and one SARA-listed species: olive-side flycatcher (Contopus coopen) were observed during wildlife baseline surveys in 2012.

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Minor impacts to wildlife will largely be due to sensory disturbance during construction and operation of the Project. Wildlife habitat and much of the landscape in the Project area has been previously disturbed by fire. Impacts from construction will be limited in duration and are not expected to result in significant adverse impacts to wildlife populations or wildlife health. During Project operations, the tailrace channel, water in-take, surge facility and powerhouse structure will be fenced to prevent wildlife from entering the areas. The Project area is part of the historic Beverly/Ahiak and Bathurst caribou herd winter migration range. The proponent conducted surveys and collected local traditional knowledge which indicated that woodland caribou are not currently found in the area and the Beverly/Ahiak and Bathurst caribou herds have not been observed over-wintering in the area for at least 30 years. The Project is located outside of the northern boundary of the SK-1 woodland caribou conservation unit as outlined in the federal recovery strategy for Woodland Caribou. The proponent has committed to developing a caribou protection plan and will continue to engage with community members from Black Lake and personnel from the ministry in the Stony Rapids area to determine the location of caribou herds relative to the Project location and develop mitigation measures if required, to minimize impacts. Technical Review Findings on the Terrestrial Environment In the EIS, the proponent presents a detailed evaluation of potential impacts, potential mitigation measures and a commitment to carry out monitoring and adaptive management should wildlife issues arise. Reviewers are generally satisfied with the assessments conducted to characterize Project impacts to the terrestrial environment. Water and Aquatic Environment Ground and Surface Water Quality Assessment of potential impacts to ground and surface water can be found in Sections 9, 10 and 11, Annex II and III, and Addendum II of the EIS. Site waste water consists of waste rock runoff, groundwater inflows during construction of the power tunnel, and site runoff water which will be collected in the settling ponds. Explosives will be used during the construction phase (power tunnel and terrace) of the Project and has the potential to change surface water and sediment quality in nearby waterbodies. In addition, waste rock runoff and groundwater inflows to the settling ponds may contain residue from the use of explosives. Modelling was conducted to predict the potential effects of project activities and settling pond discharge on the water quality of the Fond du Lac River. The surface water quality assessment in the EIS takes

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into account maximum groundwater concentrations based on the site specific groundwater sampling conducted in 2013. No parameters of potential concerns are anticipated in the Fond du Lac River as a result of settling pond discharge. Water in the settling ponds will be pumped to the Fond du Lac River after the water has been tested to confirm it meets Saskatchewan discharge criteria. Should water quality issues be detected during testing, additional treatment will be required prior to discharge to ensure protection of surface water quality. The proponent will refine the Water Quality Monitoring Program, located in Addendum II of the EIS, to help confirm protection of water quality in the Fond du Lac River during the permitting phase of the project. The program will also monitor groundwater inflow into the power tunnel during construction for quality and quantity. A summary of baseline water quality data can be found in Addendum II, Attachment Q of the EIS. Aquatic Habitat Section 12.0 of the EIS discusses potential effects of the Project on aquatic habitat including impacts to water levels, flow in the Fond du Lac River, water temperature, and impacts of the proposed weir. To maintain the water level in Black Lake, the natural flow from Black Lake to Fond du Lac River will be restricted by a submerged weir. The weir will be constructed of clean excavated rock and will span the Fond du Lac River at the Black Lake outlet. It is designed to maintain the water level in Black Lake and the uppermost section of the Fond du Lac River. The submerged weir will be designed to facilitate fish passage and flow velocities will not exceed swimming thresholds of fish species. In-water works will be completed in accordance with conditions outlined in a Fisheries and Oceans Canada Authorization and Aquatic Habitat Protection Permits. Addendum III, Attachment F provides information on river 2D modeling and water level simulation results. The proposed Project includes a water intake to direct water into the power tunnel from Black Lake. Constructing a shallow intake near the surface of the lake was preferred because it is expected to keep water temperature through the tunnel and tailrace similar to those found in the Fond du Lac River and reduces the entrainment of deep-water species such as lake trout and cisco. Discussion of the intake and fish screen is presented in Addendum II, Attachment D of the EIS. Proposed mitigation for impacts to fish habitat during in-water works include: implementation of an erosion and sediment control plan, fish salvage activities, site water management plan, and a pumphouse screen to prevent entrainment of fish. Fish habitat monitoring activities will be implemented to determine the effectiveness of the proposed mitigation including acoustic monitoring at the

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water intake and tailrace outlet, spawning surveys, mark-recapture population estimates, and temperature/ice monitoring. The ministry, Water Security Agency and Fisheries and Oceans Canada approval of the plan would be required before the proponent can obtain the necessary permits to begin construction. In response to requests by the local public, a modelling exercise was completed and presented at community meetings in Black Lake on October 29, 2013 and Stony Rapids on October 30, 2013. The model showed what the river would look like under three (400 m3/s, 210 m3/s, and 40 m3/s) reduced flow conditions at five locations. No concerns were raised after the presentation. Materials from the meetings can be found in Appendix 6.3, Appendix 10.2 and Addendum III of the EIS. Technical reviewers had concerns regarding the formation of frazil ice due to the change in Fond du Lac River flows. For frazil ice to form, an area of very cold open water must be cooled further by air temperature. Although frazil ice formation is considered likely to occur, fish of all life stages are expected to be capable of avoiding areas where frazil ice forms. Information on potential effects to fish and fish habitat that could result from frazil ice and anchor ice formation conditions in the Fond du Lac River can be found in Addendum II of the EIS. Surface ice conditions during Project operations are presented in Appendix 12.1, Addendum II and Addendum III of the EIS. Potential effects of ice formation on fish and fish habitat will be controlled through implementation of an adaptive management approach. Ice conditions will be monitored and, if effects to fish populations are identified, contingency mitigation measures would be developed and implemented based on consultation with regulators. Monitoring activities for assessing potential temperature effects and effects from ice formation during winter are describe in more detail in the Fisheries Offsetting Plan presented in Addendum II, Attachment E of the EIS. Technical Review Findings on the Aquatic Environment Regulators reviewing the EIS indicated that, should the Project be approved, a more detailed water quality monitoring plan would be required prior to construction. Additionally, due to uncertainties around the predicted impacts of water diversion on Fond du Lac River flows, aquatic habitat would also be included in the biophysical monitoring and mitigation plan required by the ministry prior to construction. Technical reviewers are otherwise satisfied by the assessment of the Project’s potential impacts on water quality and aquatic habitat and the mitigations proposed to prevent or minimize impacts.

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Atmospheric and Acoustic Environment Air Emissions Airborne emissions would be generated during construction, operation and decommissioning of the Project. The anticipated level and concentration of air emissions from the Project are discussed in Section 8, Annex I and Appendix 8.1, 8.2 and 8.3 of the EIS. The proponent undertook dispersion modelling to assess a worst case scenario related to impacts of the Project on air quality. Air parameters studied included particulate matter, nitrogen oxide (NOx) and sulphur dioxide (SO2) as the primary indicators of air quality relevant to this Project. Particulate matter of 10 microns (PM10) would be generated by construction activities including clearing, earth-moving, blasting, crushing, road building, road traffic and maintenance throughout the proposed three to four year construction period. Particles larger than PM2.5 tend to be removed from the air relatively quickly by gravitational settling. Blasting also produces small amounts of SO2 and NOx which may have potential to cause the acidification of soils and wetlands however the EIS shows the deposition of fugitive dust is not expected to lead to the acidification of soil and wetlands in the project area. Results from air dispersion modelling indicate all modelled parameters were lower than the provincial Ambient Air Quality Objectives. Upon completion of construction, the generation of PM10 will significantly reduce, with the exception of small amounts generated by the movement of local traffic on unpaved roads. Although modelling indicates ambient concentrations of dust are acceptable, the proponent will install monitoring stations to monitor PM10 emissions from above ground drilling and blasting during construction activities. Other mitigation proposed to minimize air emissions include: ensuring diesel-powered equipment is running efficiently; enforcing speed limits to reduce dust; applying water as a dust suppressant; not idling vehicles; and re-vegetating stripped areas and stockpiles where possible. Noise Noise produced throughout the Project construction phase would be similar to mining noise resulting from crushing, hauling and waste rock disposal. The total noise levels from construction activities were used to assess the noise effect. Construction activities will occur over a four year period, with varying levels of activities throughout each year. Results of the noise assessment are located in Section 8.5.5.2 and 8.5.5.3, and Appendices 8.1 and 8.3 of the EIS.

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These results predict that while construction noise at all receptors in the local area will be audible, they will not result in effects that produce changes to health and well-being and it is not anticipated that the construction noise will result in a nuisance for the people living in the area. Impacts to wildlife would also be expected to be minimal given the attenuation of most sounds with distance from source. The powerhouse will be located in a deep cut in the bedrock and insulated which will reduce noise emissions from the building during operation. Animals quickly become accustomed to new sounds as long as they are not accompanied by other sensory disturbances. It is unlikely that noise from the Project would cause significant disruption to humans and wildlife during construction and operation of the Project. Although blasting is not accounted for in the modelling or proposed monitoring, it would occur only intermittently and both the noise and vibration would be expected to attenuate substantially over distance. Additionally, blasting would only occur during the day. The detailed Blasting Plan is presented in Addendum II, Attachment A of the EIS. Technical Review Findings on the Atmospheric and Acoustic Environment Technical reviewers are satisfied with the assessment of the Project’s potential for impacts due to noise and emissions and with the mitigations proposed to prevent or minimize impacts. Residual and Cumulative Effects Section 7 of the EIS presents the proponent’s analysis of the cumulative effects of residual impacts of the Project. Details regarding residual effects can be found in the relevant portions of Section 7 and 8 of the EIS and are discussed in previous sections of this document. Cumulative effects may be associated with future activities such as exploration, utilities, access and potential expansion of other industrial development in the Athabasca region. For example, impacts could include: direct habitat disturbance; water quality and quantity effects from new industrial development; and threats to public safety and wildlife from increased traffic. Actions proposed to minimize cumulative impacts on the land include utilizing existing access roads and disturbed areas whenever possible and reclaiming disturbed sites once work is completed. Technical Review Findings on Residual and Cumulative Effects Given the uncertainties associated with predicting cumulative impacts, particularly for activities undertaken by individuals or companies other than

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the proponent, reviewers are satisfied with the assessment of cumulative effects presented in the EIS. Effects of the Environment The proponent considered how environmental events could potentially adversely affect the proposed Project. The assessment included consideration of potential short-term events, seasonal events and long-term events. Events considered include storms, extreme snowfall, extreme temperatures, high winds, fires, seismic events, seasonal events (low and high precipitation) and climate change. Climate change impacts are difficult to predict. A warmer, cooler, wetter or drier climate could influence the intensity of environmental events. The magnitude of these changes is beyond the ability of the proponent to predict. The assessment results presented indicate that considering mitigations, contingency plans and designs for each environmental event, impacts of the environment on the Project are sufficiently reduced. Additionally, conservatism incorporated into the design criteria help to address potential long-term changes in the intensity of events. The complete discussion of potential environmental effects and how they may affect the proposed Project can be viewed in Section 5.11 and Appendix 5.2 of the EIS. Technical Review Findings on the Effect of the Environment on the Project Technical reviewers are satisfied by the assessment of the potential for the environment to impact the Project and the mitigations proposed to prevent or minimize impacts. Heritage and Socio-Economic Considerations Heritage Resources The proponent’s assessment of possible impacts to heritage resources is presented in Section 16, Annex V and Appendix 16.1 of the EIS. Potential effects on heritage resources are limited to direct disturbance and loss of archaeological sites during Project construction activities. An archaeological site inventory database and literature search, elder interviews, and field assessment were carried out as part of baseline studies to determine if heritage resources were present in the heritage sensitive areas of the Project footprint. A historic Dené cemetery is within 60 m of the existing road extending north

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towards the proposed submerged weir structure. The proponent’s proposed mitigation measures are flagging off or barricading access to avoid this cemetery in the event that any road upgrade activities are planned. The Heritage Conservation Branch agreed with the findings and recommendations outlined in the baseline assessments and have no concerns with the Project proceeding. Clearance letters under Section 63 of The Heritage Property Act have been provided to the proponent for the Project. Cultural Considerations The Project is located on the Chicken Indian Reserve #224 which has been set aside for the exclusive use and benefit of the members of BLFN. Off-reserve impacts of the Project (e.g. changes to flows in Fond du Lac River) are not expected to significantly impact the ability of First Nations and Métis people to hunt, fish and trap for food or carry out traditional land use activities beyond the Project footprint. A discussion on current land and resource use is presented in Section 17 of the EIS. The proponent has formed a Project advisory committee with equal representation from the EFHLP and SaskPower. This committee will meet and review, on a regular basis, all aspects and the status of the Project including environmental, engineering and construction activities, and community matters that relate to the completion and operation of the Project. Technical Review Findings on Cultural Considerations Technical reviewers agreed with the proponent’s conclusion that additional discussions with impacted First Nations and Métis communities should be undertaken throughout all phases of the project to further examine and address the cultural impacts of the Project. Socio-Economic Considerations The socio-economic environment and the detailed assessment of potential effects to residents in the Project area are discussed in Section 19 and Annex VI of the EIS. The development of the Project would bring economic benefits to the province through taxes, water power rental revenue, employment and business opportunities. BLFN would also experience economic benefits through the revenue generated by water power rental fees. The proposed Project would create both positive and negative impacts on the social and economic fabric of the area. The proponent estimated the Project will cost approximately $500 million and will generate 450 total person-years of employment during construction for four years and six to eight person-years during operation. The construction phase of the Project will provide local economic and employment opportunities for northern Saskatchewan

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companies and residents. Conversely, the skilled labour pool may be strained trying to fill the demand for workers. As mitigation, the proponent has committed to addressing the shortage of qualified labour locally through pre-employment training programs, on-the-job training, and strategies to retain employees. The analysis of residual effects on infrastructure and community services considers potential changes to health care, childcare, education services and facilities, traffic volume, and quality and development of infrastructure. Based on the proponent’s conclusions there is no significant adverse effect on infrastructure and community services anticipated to result from the Project. After construction, new infrastructure such as roads, as well as improvement to existing roads and other facilities, will benefit the BLFN community. Another post-construction benefit for the local residents that have completed the education and training program is that their skills can be used to seek employment opportunities elsewhere in the Athabasca Basin. Larger scale benefits from the Project include increasing the production of renewable energy in Saskatchewan, as well as enhancing the supply and reliability of electrical energy transmission in northern Saskatchewan. Technical Review Findings on Socio-Economic Considerations Technical reviewers were satisfied that the proponent adequately examined and addressed the socio-economic impacts of the Project. Decommissioning, Reclamation and Abandonment Plan Section 5.7 and Addendum II, Attachment A of the EIS includes a conceptual decommissioning and reclamation plan for the Project site. The proponent indicates progressive reclamation practices will take place as Project components are completed or no longer needed. Final decommissioning will be done in compliance with federal and provincial acts, regulations, and standards applicable at the time, and in consultation with the BLFN. Major steps at the conclusion of the Project will include the dismantling of physical structures at the core facilities, removal of the submerged weir at the outlet of Black Lake, infilling the upstream and downstream ends of power tunnel to prevent access, contouring the tailrace channel and powerhouse, and reclamation of other disturbed areas. A detailed plan for decommissioning, reclamation and abandonment and financial assurance will be developed in consultation with regulatory agencies during permitting if the proposed Project receives ministerial approval under the Act.

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The main objective of the Project-specific decommissioning and reclamation plan will be to return lands disturbed by the Project activities to a condition that is physically stable, safe, environmentally sustaining and consistent with the land use and landscape of the day. Progressive reclamation is fundamental to the Project’s decommissioning and reclamation plan, whereby any disturbed area that is no longer in use will be reclaimed as soon as possible and to the extent practical. As a result, decommissioning and reclamation activities will occur throughout the operational life of the Project. Technical Review Findings on Decommissioning, Reclamation and Abandonment Plan Technical reviewers were generally satisfied with the proponent’s conceptual program for decommissioning, reclamation and abandonment. If the Project is approved, the ministry would require a detailed, comprehensive decommissioning and reclamation plan prior to the beginning of construction. This detailed plan would be reviewed every five years during operations and refined to ensure appropriate considerations have been integrated into decommissioning and reclamation activities. 4. Conclusion Members of the Saskatchewan Environmental Assessment Review Panel (technical reviewers) and the ministry conclude that the proponent has undertaken sufficient studies and provided adequate information about the proposed Project such that the EIS can be made available for public review. Invitation to Comment The public is invited to review the proponent’s EIS and the TRC and provide their comments no later than January 13, 2017. The EIS and TRC are being made available for review at the administrative offices of: Stony Rapids; Black Lake First Nation; Fond du Lac First Nation; the Environmental Assessment and Stewardship Branch, the Legislative Library in Regina; and on the ministry website at Saskatchewan.ca/environmentalassessment. Written comments received during the public review of the EIS and TRC will be considered by the Minister of Environment when he makes his decision under Section 15(1) of The Environmental Assessment Act to either: (a) give ministerial approval to proceed with the development and impose

any terms and conditions that he considers necessary or advisable; or

Public is invited to comment on the Project EIS during the public review period from December 10, 2016 to January 13, 2017.

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(b) refuse to approve the development. Contact For more information, please contact:

Alvin Yuen Senior Environmental Assessment Administrator Environmental Assessment and Stewardship Branch Saskatchewan Ministry of Environment 3211 Albert Street REGINA SK S4S 5W6 Phone: 306-787-5971 ; Fax: 306-787-0930 Email: environmental.assessment@gov.sk.ca

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