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TRANSCRIPT
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Whitebook
Hearing Responses from the Hearing Portal
for
London Mining ISUA project
Prepared by London Mining
Version of 13th March 2013
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Table of Contents
1. Hans Jørgen Løvstrøm ....................................................................................................................................................................................................................................... 4
2. Tom Pele Olsen .................................................................................................................................................................................................................................................. 6
3. NAPP (Lars P. Mathæussen og Johannes Heilman) ........................................................................................................................................................................................... 8
4. Marc Defourneaux ........................................................................................................................................................................................................................................... 10
5. Flemming Hybholt ........................................................................................................................................................................................................................................... 12
6. Peter Oluf Holm Meyer .................................................................................................................................................................................................................................... 16
7. Knud Seblon ..................................................................................................................................................................................................................................................... 20
8. Departementet for Erhverv og Arbejdsmarked 18.10.12 ................................................................................................................................................................................ 23
9. Knud Seblon II .................................................................................................................................................................................................................................................. 26
10. GEUS .............................................................................................................................................................................................................................................................. 27
11. Grønlands Nationalmuseum & Arkiv ............................................................................................................................................................................................................. 30
12. Departementet for Boliger, Infrastruktur og Trafik, Afdelingen for Infrastruktur, Klima og Energi ............................................................................................................. 33
13. ICC og WWF ................................................................................................................................................................................................................................................... 42
14. Flemming Hybholt ......................................................................................................................................................................................................................................... 69
15. Landslægeembedet ....................................................................................................................................................................................................................................... 76
16 TIMMIAQ ........................................................................................................................................................................................................................................................ 81
17. Grønlands Arbejdsgiverforening .................................................................................................................................................................................................................... 89
18. Kommuneqarfik Sermersooq ......................................................................................................................................................................................................................... 98
19. SIK ................................................................................................................................................................................................................................................................ 117
20. Departementet for Sundhed ....................................................................................................................................................................................................................... 124
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21. Nuuk Fjords Venner ..................................................................................................................................................................................................................................... 149
22. Janus Kleist................................................................................................................................................................................................................................................... 155
23. Arbejdstilsynet ............................................................................................................................................................................................................................................. 160
24. KANUKOKA ................................................................................................................................................................................................................................................... 162
24 A. KANOKOKA (Bilag A – Qaasuitsup Kommunia) ......................................................................................................................................................................................... 184
24 B. KANOKOKA (Bilag B – Qeqqata Kommunia) ............................................................................................................................................................................................. 186
25. Birger Poppel ............................................................................................................................................................................................................................................... 187
26. Avataq .......................................................................................................................................................................................................................................................... 202
28. Jacob Mathiassen ........................................................................................................................................................................................................................................ 211
29 Jakob Mathiassen II ...................................................................................................................................................................................................................................... 231
30. Departementet for Fiskeri, Fangs tog Landbrug (APNN) – Department of Fiskeries, Hunting and Farming .............................................................................................. 232
31. Dep. for Indenrigsanliggender, Natur og Miljø (NNPAN) ............................................................................................................................................................................ 236
32. Peter Barfod ................................................................................................................................................................................................................................................. 251
33. Grønlands Politi ........................................................................................................................................................................................................................................... 254
34. DCE/GN comments to the EIA for the ISUA project .................................................................................................................................................................................... 261
List of Abbreviations
BMP Bureau of Minerals and Petroleum
DCE Danish Centre for Environment and Energy
EIA Environmental Impact assessment
GN Greenland Institute of Natural Resources
LM London Mining
SIA Social Impact assessment
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1. Hans Jørgen Løvstrøm
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
1.1 I hereby forward my proposal: As Nuuk Fjord
is beginning to get pack ice, I propose that the
‘loading port’ moves to Fiskefjorden which
was used for navigation to the olivine mine
port. There is no pack ice in this fjord.
Qussuk, Ilulialik and Aningaannaq should not
be used, because those places are important
to caribou.
To select a port site is a significant engineering work
which involves many factors. SNC-Lavain, the
engineering consultant, has put great effort into
localizing the most suitable site for port location for
the ISUA project and several options have been
carefully considered. A port at Qussuk has been
found to be the best site because of (1) favorable ice
conditions in this part of the Godthåbsfjord
throughout the year, (2) easy access for large bulk
carriers through the wide and deep fjord, and (3) the
land at Qussuk is relatively level which facilitates the
construction of the port facilities, and (4) lower costs
for access road and pipeline constructions.
Furthermore, the EIA has shown that the impact on
Caribou in the selected area is low.
In addition to many reasons that have been
discussed, the Fiskefjord is very narrow. Safe
navigation with large bulk carriers to the port site
proposed by Hans Jørgen Løvstrøm will be very
questionable.
DCE/GN: The proposal made by Hans Jørgen Løvstrøm would provide less impact of the area around Qussuk. DCE/GN assesses that the suggested placement, with associated modifications of the road routes, will have similar negative effects on caribou population’s use of the area. The proposed route goes parallel with caribou migration routes, while a road to Fiskefjord will cross the routes.
None
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1.2 It is proposed to build a pontoon bridge (big
barges can be built into a bridge, and because
Tasersuaq is fresh water, the material will not
rust).
(I’ve seen on TV, that the American military
can make pontoon bridges to transitions of
tanks fast).
To build in the inland Qussuk (Narsarsuaq?)
would be very difficult and expensive,
because the soil is very soft (muddy).
The engineering firm SNC Lavalin has studied very
carefully on all engineering issues on the project.
The current design concepts are concluded as the
most feasible ones. The proposed concept in this
comment is technically not feasible to provide a safe
and reliable option. The geotechnical conditions
were investigated carefully for all sites to ensure
that the structures can be built that meet the design
requirements.
DCE/GN: No environmental aspect. None
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2. Tom Pele Olsen
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
2.1 What is the economic benefits of Isukasia -
Can you provide a comprehensive explanation
of this? 32 billion is mentioned in revenue -
link:
http://dk.nanoq.gl/Service/Hoeringsportal/Mi
lj% C3% B8vurderinger/2012 / ~ / media /
Naalakkersuisut / Raasto f / Hoeringsportal /
Exploitation Permit% 20London%
20Mining/Borgerm% C3% B8de%
201/Referat% 20Borger m% C3% B8de%
20I_dk.ashx)
But it not shown in details how the revenue
will be paid, is it only after 30 years or already
from 5/10 years? what is the annual revenue?
'When the director of London Mining
presented, he mentioned that Greenland will
have an income of 32 billion. However, we
know from the olivinemine, which has
announced that it will provide income for 80
Revenues will start to appear from the start of
construction works in the form of income tax - also
from foreign staff.
In addition, London Mining will pay dividend tax
immediately after one year of operation and
corporation tax will be paid starting after 3 and 4
years of operation after final amortisation of
investments.
At the same time, subcontractors to the project will
pay taxes of their profits. This applies to both
foreign and Greenlandic companies. This means that
already the year after start of construction works
taxes will be paid by subcontractors.
Corporation and divident taxes are estimated based
on the forecasted market prices of iron ore and
estimated operating costs.
DCE/GN: No environmental aspect . None
7
years, that due to the world market this
lasted only for 4 years. Can London Mining
guarantee that Greenland will have 32 billion
in revenue? '
2.2 The social conflicts: I can not read from your
conclusions how the different cultural values
are being tackled, as crime and murder /
robbery / rape and other crimes – how will
this be tackled in relation to international
workforce with a different cultural
backgrounds/standards and how will
theinternational workforce be punished. The
current legal system practices in Greenland is
intended for Greenlanders-how does this
work for international workforce? Equally
with the existing legalsystem?
Comment is a matter for the Government of
Greenland.
BMP: There will be no difference in how foreign workers will be treated in the legal system compaired with workers from Greenland.
DCE/GN: No environmental aspect .
None
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3. NAPP (Lars P. Mathæussen og Johannes Heilman)
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
3.1 The Godthåb Fiord is used daily by fishermen
and hunters, and when the mining is initiated,
there will be a big loss in fishing and hunting
profession. What is the plan for this loss?
The project operations do not expect to create big
losses in fishing and hunting activities. In fact, the
presence of large amount of workers on site during
the construction and operations will most likely
encourage these activities as LM is planning to
engage directly with the local fishmen and hunters
for fish and meat supplies. This plan is to be part of
the IBA negotiations. A monitoring plan will be in
place in order to study carefully the situation and, in
case such losses are identified and proven with a
solid scientific basis, possible compensation
mechanisms would then be negotiated.
DCE/GN: No environmental aspect. None
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3.2 As known, the fishermen and hunters from
Nuuk use the Godthåb Fiord on full time
basis, and when the mining is initiated the
majority be lost, therefore we request, that
Naalakkersuisut will create a fund for those
who will lost in livelihood, so that the users
can get replacement.
Our request cannot be rejected, because it’s
in the UN determined, that one should do
something about everyone, who is politically
affected in his profession.
It is not expected that the mining operations will
impact these areas significantly. A monitoring plan
will be in place to study the facts and relevant action
plan will be determeined accordingly by the
Government of Greenland and London Mining.
BMP: Issues related to establishment of
fonds etc. will be a part of the Impact
Benefit negotiations taken place in
2013.
DCE/GN: No environmental aspect.
None
3.3 With this short explanation, we request that
this work starts as soon as possible, and we
would suggest that the work is initiated in
cooperation with the organization KNAPK.
Comment noted. DCE/GN: No environmental aspect. None
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4. Marc Defourneaux
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
4.1 Has there been a thorough archaeological
survey of all northern residents and Inuit sites
in the area?
The National Museum and Archives has surveyed the
project area in 2008, 2009, 2011 and 2012. The
reports from the surveys are available from the
museum. The conclusion of the surveys is that
although many new archaeological sites were
discovered, none of them will be disturbed by the
Isua project. Furthermore, continuous collaboration
with the Museum will be maintained during
construction.
DCE/GN: No environmental aspect. None
4.2 How will sewage water be treated? Will there
be a wastewater plant?
All sewage water will be collected and treated in
state-of-the art sewage plants fulfilling effluent
criteria specified by the BMP.
DCE/GN: Nothing to add. None
4.3 Why will London Mining use fossil fuel and
not renewable energy?
Can Greenland send a delegation to Sierra
Leone where London Mining has a project, to
see how it works?
LM does not have the right to use the water in the
project area for hydropower. In spite of this, LM
requested International Engineering firm SNC-
Lavalin to study the hydropower alternatives for the
Isua project. This study is available to the Public.
The financial analyses show that the capital
investment has a very significant impact to the
project economics. An accurate financial analysis has
to take all factors into the evaluation, including the
project capital cost, operational cost, production
rate, estimated near term and long term product
BMP: There are no exact plans of
visiting Sierre Leone, but the Greenland
Authorities are looking at mining
experiences from other countries.
DCE/GN: Nothing to add.
None
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prices, financing conditions and freight
arrangements etc. The financial indicators in the
hydropower alternative study show the economics
of the project not feasible under the construction of
power dams and transmission lines. The simple
calculation that is reported by this comment cannot
reflect the real project economical condition. Based
on the financial model developed by SNC Lavalin, the
increased capital expenses combined with the
estimated delay for the production will make the
project not financially attractive.
LM’s project in Sierra Leone is located in a tropical
environment and is currently extracting minerals
from tailings from previous mining activities. This
project is therefore not comparable to the Isua
project at its current condition. However, LM
welcomes visiting delegations from Greenland
Government.
4.4 Will there be a referendum on the project? Government issue. BMP: There will be no referendum.
Greenland has Self-Government, and
the people have democratically elected
the members of Inatsisartut
(Parliament), which again has elected
Naalakker-suisut (Government).
Wether the project should be approved
or not, is decided by Naalakkersuisut.
None
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5. Flemming Hybholt
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
5.1 Please find enclosed a comment regarding the
opportunities to use hydropower as the
source of electricity to the mine project.
Investment in hydropower as the source of
energy to the ISUA iron mine instead of the
planned very expensive and polluting diesel
generators. Operation costs of 1.8 billion DKK
up front and interest. Investment in diesel
generators and oil storage 1.7 billion DKK.
Value of electricity from hydropower 1.8
billion DKK. Gross investment of 3.5 billion
DKK. Investment compared to diesel
production 1.8 billion DKK. NPV 11.5 billion
DKK over 15 years with a discount rate of 8 %.
Reduction in emissions of CO2 at 450,000 tons
annually. This prevents almost a doubling of
CO2 emissions in Greenland.
Overall a very economically and
environmentally very advantageous
investment. The basis for the calculations is
the material on hydropower alternatives
LM does not have the right to use the water in the
project area. In spite of this, LM requested the
International Engineering firm SNC-Lavalin to study
the hydropower alternatives for the Isua project.
This study is available to the Public. This study
concluded that the secure hydropower within the
economic viability is 120 MW.
A decision to use hydropower also involves financial
analyses. In that respect it should be noted that the
capital investment has a very significant impact to
the project economics. An accurate financial analysis
has to take all factors into the evaluation, including
the project capital cost, operational cost, production
rate, estimated near term and long term product
prices, financing conditions and freight
arrangements etc. Simple calculation as reported by
this comment cannot reflect the real project
economic condition.
Based on the financial model developed by SNC-
Lavalin, the increased capital expenses combined
with the estimated delay for the production will
make the project not financially possible.
The present CO2 emission from Greenland is
DCE/GN: In this, as in several other
comments, the use of fossil fuel instead
of whole or partial utilisation of the
hydropower potential in the area, is
criticised.
DCE/GN agrees with this view, but must
also point out that there has not been
prepared an EIA for the use of
hydropower resources.
None
13
prepared by London Mining. estimated to around 0.63 million tons per year
(average of 2002 – 09). The ISUA project will add
0.56 million tons per year in the operational phase
using fossil fuel (diesel) – i.e. in total around 1.2
million tons per year (using the present emission
from Greenland as basis).
These figures can be compared with annual CO2
emission from Denmark of approximately 50 million
tons per year and with the global CO2 emission of
around 31,800 million tons (2010 figures). The
estimated emission from Greenland - including the
Isua project - is thus 0.0038 % of the global emission.
Consequently, the emission share from Greenland is
among the least CO2 emitting countries. Greenland
was ranked no. 183 out of 217 countries (in 2010)
and be ranked around no 172 when the ISUA project
is accounted for.
5.2 During the public hearings, London Mining
stated that they are open for a supply of
hydropower to the project, but that they have
a number of reservations that need
clarification.
It is London Mining’s view that it would be a
problem to get access to the hydropower
potential in Imarsuup Isua, as this potential
has been committed to an aluminum melter
project. This situation must of course be
clarified by Naalakkersuisut. In this relation is
An engineering study has different accuracy levels.
LM is not sure what engineering levels and
development stages were used for other
hydropower studies which were prepared by other
consultants for other project.
DCE/GN: Nothing to add. None
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should be remarked that there are other
sources of hydropower, which can ensure
hydropower supply to the aluminum melter
project.
London Mining is of the opinion that the
hydropower potential of Imarsuup Isua only
can supply 120 MW and hence will not ensure
the total electricity need. However, the
hydropower potential of the aluminum melter
project is estimated to 175-200 MW, which
have a nice margin to cover the total needs.
London Mining’s material calculates a
construction period for hydropower to 7
years, which either leads to a three-year delay
of the project, and thus a poor economy or
the need for the establishment of a diesel
power plant for use in the project’s first
operating year, which naturally leads to an
increase in net investment of up to 1.8 billion
DKK. Hereby NPV gets reduced by the
hydropower investment to 9.7 billion DKK.
When referring to the hydropower potential’s
stage of development, and lessons learned
from the construction of hydropower plants in
Greenland (Ilulissat 2.5 years) and Iceland
(Budarhals 95 MW, 3 years) there seems to be
basis for a much shorter construction period
than 7 years, and thus an opportunity to plan
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mining project without establishment of diesel
generators.
Based on the above, there seems to be good
reason for a careful assessment of both
economic and environmental nature in
connection with an approval of this
application from London Mining.
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6. Peter Oluf Holm Meyer
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
6.1 Consultation response regarding London Mining’s - ISUA Iron Mine Project in Qugssuk at the bottom of Nuup kangerlua and next to the inland ice.
Positive and responsible exploitation of our
mineral resources.
It makes a positive impression on one as a
citizen, that the Self Government with 'one
hand' for the last 20-30 years has established
hydropower plants that supply much of the
country with sustainable renewable energy
which does not pollute, and continue to
develop / build this form of energy to replace
polluting diesel power stations around the
country.
At the same time, we have the last 20-30
years heard from our responsible leaders, that
sustainable renewable energy in the form of
hydropower is the way forward, when the
extraction of our mineral resources will
contribute positively and responsibly to
Greenland's future income, since our
hydropower potential is so great in this
As far as to the use of hydropower, see answer to
question number 5.1.
However, it should be noted that London Mining
does not have the right to use the hydropower
potential in the project area. In spite of this, LM
requested the International Engineering firm SNC-
Lavalin to study the hydropower alternatives for the
Isua project. This study concluded that the secure
hydropower is 120 MW. LM is not aware how Alcoa
made their calculation of the hydropower resources.
BMP: comment regarding the COP 18 is noted.
DCE/GN: Nothing to add.
None
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country.
Therefore, it creates a negative impression on
one as a citizen, to be informed at the public
meetings that Greenland will stand outside in
the forthcoming international environmental
conference COP18, organized by the UN.
Based on the argumentation that now
Greenland, with 'the other hand' would have
the possibility to pollute the environment
unlimited when large scale mining projects is
to be realized in our scenic Greenland.
This is largely reflected in London Mining’s
application, which states that the mine is
planned to be operated by use of fossil fuels
with polluting power stations, which is based
on to London Mining's own studies showing
that hydropower potential is too "small" in the
area. This question was also put forward at
the public consultation meetings and there is
obvious doubt if this is correct, since other
studies appear to show significantly higher
hydropower potential.
6.2 London Mining informs an expected
consumption of arctic diesel of 210 million
liters per year in the planned 15 years or
more.
-In order to be able to imagine the huge
amount of what the diesel consumption will
Reference is made to the answer to question
number 5.1.
As far as transportation and unloading of diesel for
the project is concerned, it is correct that a special
build tanker will supply the project with fuel roughly
once a month. This tanker will be similar to the ones
DCE/GN recommend that specific environmental requirements are set for the handling and use of fossil fuels in Isua project, which will ensure minimal risk and impact on the environment during operations and in case of spills. Unloading and loading must be done
None
18
be per year, and for the comparison of
proportions, I found a press release from
Nukissiorfiit concerning Ilulissat’s energy
consumption for the production of the city's
electricity.
The press release states that Ilulissat in 2013
should revert to hydropower and that the
local diesel-powered electricity plant today
consumes 6 million liters per year.
-Thus, London Mining will annually consumer
and pollute the environment equivalent to 35
times the annual consumption in Ilulissat and
3 times Ilulissat’s annual consumption per
month.
-This will, by the combustion pollute the
environment with an unacceptable extent
within our scenic area, while there will be an
unacceptable risk to the environment in
connection with the unloading of the fuel to
the bottom of Qugssuk with tankers that can
accommodate up to 30 million liters of diesel
oil per time. According to the application will
boarding happen 12 times a year / 1 time a
month.
According to the country´s laws this
contradiction with the text of the law that
outline, that the best available (and least
polluting) energy source should be used.
It would therefore be feasible if London
that supply other towns and settlement s in
Greenland with fuel. However, in the case of the
ISUA project arctic diesel has been specifically
chosen. This fuel type has operational advantages in
cold climates and also environmental benefits
compared to other types of gasoils and heavy fuels.
Arctic diesel oil has less content of Sulphur (S), lower
emissions of soot and furthermore advantages in
case of spills (lower content of parafins. The
unloading facility at Qussuq port will be constructed
to the highest standard and for example includes
pressure sensors that immediately stop the
unloading in case of a leak.
under satisfactory safe conditions and with robust systems that take into account the ice and weather conditions. Unloading and loading must meet high standards which ensure that the risk of accidents / spills are as small as possible and that the consequences of any spill are as small as possible. A plan for handling spills in case of accidents must be prepared and approved by the authorities.
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Mining and others, as far as economy and
time schedule are concerned, are required to
plan the mine project is close cooperation
with the country’s authorities in such a way
that the project are based on the available
hydropower resources. This should be done
without taken into account how long the mine
project will run, because the hydropower
plant will be beneficial to Greenland as an
energy source that can be used by other,
when the mine is closed.
6.3 Moreover, it is in any case desirable that the
mining company are required to make
sufficient financial guarantees before the
construction, which the Self Government can
make use of if the clean-up does not happen
in an acceptable and satisfactory manner
during exploitation and when the mine is
being abandoned.
It is standard procedure for mine projects in Greenland that the mine company before any construction works can initiate to deposit according to the progress of construction an amount that equals the estimated closure cost of the constructed facilities. The amount must be approved by the Greenland Government and will be adjusted if changes subsequently are made to the mine project.
DCE/GN: Nothing to add. None
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7. Knud Seblon
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
7.1 I am a user of Nuuk fjord like many others.
We hear from a marine biologist during the
fourth consultation in Katuaq that other
countries keep the dangerous chemicals
separated from nature. They are not poured
out and mixed with the nature.
The same should happen here. Dangerous
chemicals should be kept away from Nuuk's
lakes, rivers and fjords. Pure nature costs, but
is worth every penny.
The same question was raised as part of the 3rd
public hearing meeting on 24 September 2012.
Please confer the detailed answer included as no. 4
of the reply from the meeting available on the BMP
web portal.
BMP: Discharge to the nature has to
follow international best practice and
the requirements in the government
approvals has to be set after guidance
of DCE and GN.
DCE/GN: The question is answered in
the minutes of the third public meeting,
section. 4: ”On behalf of
Naalakkersuisut has the DCE developed
”Greenland Water Quality Guidelines
(GWQG)” that gives the suggested
maximum concentrations in ambient
water. There are specific values for
freshwater (rivers and lakes) and salt
water (for example the fjord). The
ambient water quality is defined from
international eco-toxicologigal
standards. Based on this the quality of
the discharged water is defined. This
includes a dilution factor. This is the
normal international praksis. Some
areas have natural heigh levels of
metals.
None
21
Among the substances that will be
discharged to the marine environment
for which a GWQW value has been
defined, only cobber and iron will
exceed the values in the surrounding
water. The dilution required for these
metals to be below the GWQW is small
and will be achieved close to the
discharge point. There can also the
small amounts of chemicals in the
water. In particular the three reagents
Xanthate, Flotigam og Magnafloc .
When these reagents are discharged
they can occur in toxic concentrations.
However due to the local conditions
including the tide, the dilution in the
Taserâssuk bay which is bordered by
one of the wharfs will quickly be meet.
All requirements of the BMP will be
meet outside the port area including
Qugssuk.
All chemicals and products that are
used in the process must be approved
by Naalakkersuisut before they are
used. Limit values will be defined for
these chemicals in discharged water.
These limits will follow EU standards.
The limits will secure that there will be
no toxic effects on the environment
outside a dilution zone of 100 m.
22
Chemicals that can be accumulated in
the environments or organisms will not
be permitted. Similar requirements will
be enforced for heavy metals outside
the dilution zone.
It will be continuously controlled by the
company and by the authorities that the
limits are met. In addition the
environmental monitoring will include
the concentrations of metals and
chemicals in water, sea-weed, fish,
mussels and the sea floor. Monitoring
of toxic effects on sea-weed, mussels
and fish will also be carried out in the
project area and a reference area.
23
8. Departementet for Erhverv og Arbejdsmarked 18.10.12
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
8.1 Consultation responses from Dep.for business
and labor regarding Social Impact Assessment
(SIA) and Assessment of impacts on
environment of the Isua iron ore project (EIA).
By the letter dated 16.august 2012, the BMP
requests for consultation responses regarding
reports EIA and SIA in the London Mining
Greenland A / S's application for an
exploitation license for an iron mining project
in Nuuk.
No response is required. DCE/GN: Nothing to add. None
8.2 Ministry of Industry and Labour has the
following comments on the Social Impact
Assessment (SIA):
1. Generally, it is assessed that the project
would help if the government coalition aims
to create a more self-sustaining economy
including by exploiting Greenland non-living
resources, for example mining. It is expected
to be done by a considerable job creation and
thus improved tax bases primarily in the
operational phase as well as corporate taxes
Capacity development and education has high focus
for London Mining, in order for London Mining to
recruit as many local qualified workers as possible.
The actions that London Mining will take and the
support London Mining will give to the education
system will be part of the negotiation of the IBA.
DCE/GN: No environmental aspect. None
24
and fees.
It is positive that the project aims to employ
as many local qualified candidates. It is also
noted that the employment impact of the
construction phase depends on how quickly
local companies can be ready to meet the
needs of the project during the construction
phase.
This is exactly one area where the department
has put initiatives, in the form of tutoring and
educational activities for companies that
might bid on the tasks associated with large-
scale projects.
It is also noted that there may be some
conflict with other economic sectors if the
competition for qualified staff means that
other sectors will find it difficult to attract
sufficient labor.
This situation should therefore be closely
followed with a view to implementing
measures to ensure an adequate supply of
labor.
Finally, it is noted that the largest
employment impact of the project will be
linked to job creation during the operational
phase.
It is in this context positive that it expects to
25
start recruiting labor from Greenland to
training already in the construction phase.
The department has no comments on the
Environmental Impact Assessment (EIA).
26
9. Knud Seblon II
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA
9.1 Other mining countries require that these
chemicals are kept separate from nature. It is
not discharged to fjords and mixed with
nature (animals and plants). The same should
happen here. These chemicals must be
filtered out and not poured directly into
Nuuk's lakes, rivers and fjords. The chemicals
must be removed from process water before
discharging the used contaminated water
further out to the fjord at the harbor. This
natural cost but it is worth the money.
The same question was raised as part of the 3rd public hearing meeting on 24 September 2012. Please confer the detailed answer included as no. 4 of the replies of the meeting.
DCE/GN: See comment to section 7.1. None
27
10. GEUS
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
10.1 GEUS has received and reviewed the hearing
report re. the Isua project.
Although SIA and EIA is not part of the core
competencies related to mining GEUS has the
following overall remarks to be highlighted as
part of the hearin.
No response is required. DCE/GN: Nothing to add. None
10.2 Will there be ensured a continuous
monitoring and control of production data
from the mine?
GEUS is keen to be involved in a further
dialogue on this issue In order to ensure the
best possible recording and storage of data.
Comment is a matter for the Government of
Greenland .
BMP: The ore production will be
monitored based on the production
data given by the regularly reporting
from LM. BMP has an agreement with
GEUS concerning evaluation of these
reports.
DCE / GN recommend ongoing
monitoring, as proposed by GEUS.
Monitoring of production data vilgive an
opportunity early on to detect
significant changes in the ore chemical
composition. Changes in ore chemical
composition could have environmental
effects
None
10.3 It should also be ensured that in connection
with the exploitation activity, that at any time,
London Mining will follow the regulations established
by Greenland government.
BMP: BMP has regular inspections of
the mining activity and if necessary
None
28
there should be access to geological sampling
under § 2 stk.4 in the Act of Inatsisartut # 7 of
7 December 2009.
consultants will be used.
DCE/GN: Nothing to add.
10.4 Currently, there is a work ongoing to preserve
selected areas of the Isua resource to GeoSite.
GEUS calls in this relation to finalize this work
and that the area will be preserved before
construction is initiated since otherwise it
would damage the sites during construction.
Comment is a matter for the Government of
Greenland .
BMP: The geo-site mentioned is the
locality where the oldest carbon in the
world has been detected. This geo-site
is outside the mining area but might be
in the vicinity of the road and the
pipeline. The geo-site will be kept as it is
and will not be affected by the mining
activity.
DCE/GN: Nothing to add.
None
10.5 The planned 105 km gravel road between the
mining area and the port will open up for a
unique infrastructure in an otherwise
impassable area. It should therefore be
secured that possible other exploration
companies will have access to use this
infrastructure to transport equipment and
material assuming it is safe and
environmentally acceptable.
The 105 km access road will be privately owned by
London Mining. However, when possible, London
Mining may approve for others to use it for non-
commercial purposes. London Mining reserves the
right to reject applications that are not
environmentally acceptable, have safety concerns,
impact London Mining’s operations or may violate
the legal rights of London Mining.
London Mining agrees with DCE that that approval
by BMP is also required. In the case of such a
demand, London Mining will expect that the third
party user of the access road submit a
comprehensive application for the purpose of the
use, duration, safety aspects, traffic aspects and
environmental aspects.
DCE/GN recommends that use of the road by other companies should also be approved by BMP. This is important to secure that the possible environmental effects of cumulative impacts are assessed.
None
29
10.6 In order to assess the project in more detail
the ressource and production estimates used
in the feasibility study are needed. GEUS
would like to receive copies of this
information in order to assess which
requirements London Mining should be asked
to meet regarding documentation and
reporting in a production phase.
Comment is a matter for the Government of
Greenland .
BMP: BMP has rules and requirements for reporting, which will be sufficient in this case. It is not a complicated ore and there is no reason for providing GEUS with more detailed information concerning the BFS and its estimations.
None
30
11. Grønlands Nationalmuseum & Arkiv
No. Question in English Response from London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
Comments from the Greenland Museum
(Grønlands Nationalmuseum & Arkiv)
regarding the Environmental Impact
assessment and Social Impact assessment
which have been prepared in connection with
London Mining Greenlands’s application for
opening an iron mine near Nuuk.
- -
11.1 Regarding section 0.8.2. page 36: We propose
that the last line “and moved if relevant” is
removed since it doesn’t make sense to move
an archeological find.
Comment accepted. DCE/GN: Nothing to add. Last part of
the sentence
”will be
moved if
relevant” will
be deleted.
11.2 Regarding section 5.4.3. Archeological finds:
pages 140, 141 and 142:
We do not think the wording is good and fully
correct. We therefore propose the following
text instead:
The inner parts of Godthåbsfjorden-area has
been used by people through 4000 years. All
the cultures which has lived in Westgreenland
since 2000 f.Kr. have based their settlement
Comment accepted. DCE/GN: Nothing to add. Proposed
wording will
replace the
current text.
31
along the coast on also utilizing the inland
population of Caribou.
Sources such as Aron from Kangeq describe
how the caribou hunting in the inland took
place in the middle of 1800. Groups of people
travelled during the summer in boats and
kayaks into the fiords and established camps
in areas with good access to the inland. From
there the people went further inland and
established settlement, from where they went
caribou hunting. A characteristic of the inland
area where London Mining’s activities will
take place, are numerous constructions with
stonewalls. The hunters have returned to these
houses for generations. There are also other
signs of hunting activities. These signs are
from hunting tours and hunting activities such
as tent-rings, so-called huntersbeds (for
individual sleepover), stone structures to hide
behind during hunting etc.
Previously, there has only been carried out
very few archeological surveys in the inland of
the Godthåbsfjorde. In 2008, 2009 and 2011
Nunatta Katersugaasivia Allagaateqarfialu
(Grønlands Nationalmuseum & Arkiv) carried
out archeological surveys in the areas of the
mine project, including the mine area, the
roads and the pipeline and harbor area /
32
GMNA 2008, GMNA 2009, GMNA 2011/. The
field work was supplemented with literature
studies. An additional detailed study of the
final allignment of the road between the port
area and Crossing 1 (also called Maqqaq
Qulleq) was finalized in September 2011 /
GMNA 2011 /. These survies did not show any
signs of archeological finds of significant
importance. The survey of the remaining part
of the alignment from Crossing 1 to processing
plant was postponed due to bad weather in
2011 but carried out in 2012 by Greenland
Nationalmuseum & Arkiv.
33
12. Departementet for Boliger, Infrastruktur og Trafik, Afdelingen for Infrastruktur, Klima og Energi
No. Question Response in London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
12.1 Division Infrastructure, Climate and Energy
consultation responses to London Mining
application for exploitation license for the
Isua project.
This consultation response includes comments
from the Division of Infrastructure, Climate
and Energy on the EIA (Orbicon A/S, 2012) of
the Isua Iron Mine Project. The comments
relates to (1) greenhouse gas emissions, (2)
alternative energy (hydropower) and (3)
short-lived climate forces' (SLCF).
Preliminary general comments:
With reference to the Mineral Resources Act
the EIA refer to a requirement the use of BEP
and BAT in project planning. As a consequence
it would provide more transparency if it is
described which standards are followed in
each case since the Greenlandic authorities
have not established standards for acceptable
environmental pollution levels.
It would be useful to specify why reference
has been made to U.S. environmental
authorities EPA standards in the section on
London Mining is committed to build the mine at
Isua to the highest standard. This implies using Best
Available Technique (BAT) and BEP. London Mining
considers the various standards mentioned in the
EIA as benchmark for the mine industry and have
consequently been proposed for the project.
US EPA emission standards for non-road diesel
engines, for mine equipment and haul trucks, are
slightly stricter than EU standards. The US EPA Tier 4
standards (2014) for engines 130 to 560 kW are
essentially identical to EU Stage IV standards, but
slightly stricter for PM: 0.02 g/kWh vs. 0.025 in the
EU standard. EPA has standards for engines > 560
DCE/GN: Nothing to add.
None
34
dust and air pollution. For motor vehicles, the
World Bank's IFC standards for emissions of
air pollutants in large-scale projects in
developing countries (is used) and EU
standards of protection of human health and
vegetation. We recommend that in each case
the highest standard is used, and that that any
deviations from this will be further explained,
if this is the case.
kW but EU does not.
EU ambient air quality standards are used in
dispersion modeling since they apply throughout
Europe. Danish C-values for ambient concentrations
are normally applied in dispersion modeling using
the OML model. OML could not be used due to the
complex terrain. The AERMOD model used does not
provide the exact statistic required for evaluation of
compliance with C-values, so only the EU ambient
limit values could be tested for compliance.
World Bank/IFC emission standards for diesel power
plants are referenced since the EU Large
Combustion Plant Directive does not apply to diesel
engines and emission limit values in Miljøstyrelsen’s
Guidelines for Air Emissions (2001) do not apply to
large diesel engines. Danish emission standards in
Departmental Order no. 621 of 23/06/2005 could
apply, giving a lower NOX emission limit value. The
air pollution dispersion modelling assumes World
Bank NOX emissions, which makes the dispersion
results for NO2 more conservative. The area of NO2
exceedance would be smaller if the Danish emission
standards had been used when calculating power
plant emissions.
Air qualiy assessment and assumptions for the
modelling are detailed in Annex 4 of the EIA and
summerized in section 7.1.8 of the main EIA report
35
12.2 Emissions of greenhouse gases
Department of Infrastructure, Climate and
Energy notes that greenhouse gas emissions
will result in an estimated increase of
Greenland's annual greenhouse gas emissions
during the operational period by 89%
(excluding maritime emissions that are
supposed to be significant). This will result in
a total emission per capita of approx. 21 tons
of CO2, against the current per capita of
approx. 11 tons (average from 2002-2009).
The increase will bring Greenland in line with
the 10-15 largest per capita CO2 emitters in
the world. For comparison, the EU's total per
capita emissions are 7.5 tons. In Saudi
Arabia’s it is 16.5 tons and in the United Arab
Emirates 24.9 tons.
The method used (section 3.5) for the
assessment of the impact on the environment
of the mining activities in relation to any local
or regional impact, and the model is therefore
not appropriate to describe a climatic
significance. The project's climatic significance
must be considered high.
Compared to the coalition agreement (of the
Greenland Self Government) and the 2025-
plan which claims to economic development
must be accompanied by a general principle
of sustainability, which also includes
environmental and climate sustainability, it is
The present CO2 emission from Greenland is
estimated to around 0.63 million tons per year
(average of 2002 – 09). The Isua project will add 0.56
million tons per year in the operational phase using
fossil fuel (diesel) – i.e. in total around 1.2 million
tons per year (using the present emission from
Greenland as basis).
These figures can be compared with annual CO2
emission from Denmark of approximately 50 million
tons per year and with the global CO2 emission of
around 31,800 million tons (2010 figures). The
estimated emission from Greenland - including the
Isua project - is thus 0.0038 % of the global emission.
Consequently, the emission share from Greenland is
among the least CO2 emitting countries. Greenland
was ranked no. 183 out of 217 countries (in 2010)
and be ranked around no 172 when the Isua project
is accounted for.
The recommendation of using hydropower is noted.
See also the remarks in 12.3.
DCE/GN: Nothing to add. None
36
recommended that London Mining base its
energy supply on the available hydropower
potential.
Other climate and energy benefits of this
disposition are further specified in the
following.
12.3 Hydropower and energy supply
In the EIA report hydropower is excluded as an
alternative with reference to the long
construction period compared to the overall
mine life and because of the lower net present
value (NPV) of the project. It is also made
clear that the potential is not readily available
since the resource may be allocated to other
projects. However, from the minutes from the
2nd public hearing meeting on the 7.
September 2012 London Mining made it clear
that it is happy to shift from diesel power to
hydropower “when this becomes available”
(no page number given in the minutes). If this
is the case, that LM wishes to build a
hydropower plant during the operation phase
if the possibility becomes available we suggest
that the possibility of using hydropower is
studies further and is included in the project
design.
An option could be to use diesel during the
construction phase and shift to hydropower
As mentioned at the 2nd public hearing meeting in
Nuuk on the 7th September 2012 London Mining
would be happy to replace, in part or whole, diesel
power with hydro power, if made available by
others. But this requires that the hydropower dams
and transmission lines are constructed and financed
by a third party and the price of the power is
commertially competitive. London Mining cannot
build and operate a hydropower plant for the
reasons given in the answer to question number 5.
DCE/GN: Nothing to add.
None
37
during operation.
A hydropower plant will lead to much reduced
CO2 emissions and to much lower emissions
of sod and other air pollutions according to
the EIA report. If more industries could use
the electricity from a hydropower plant and if
the energy demand in Nuuk could be secured
for the future it would be economically
beneficial. The consequence would be a
reduced carbon footprint or CO2 footprint.
12.4 Energy supply
It should be investigated if plans for the
energy supply for energy demanding industrial
projects could be integrated with the energy
supply plans for the region. An analysis of
possibilities that include the strategic plans of
Nukissiorfiits for the future energy supply in
Nuuk points to the following issues that could
be taken into consideration when a final
decision is taken regarding the projects (Isua
project) energy supply.
The Buksefjord hydropower plant which
supplies Nuuk is expected to be enlarged
between year 2020 and 2040 to meet the
increasing needs in Nuuk, where the energy
consumption is increasing and is expected to
reach 70 MW in 2030. The need (for more
Comment is a matter for the Government of
Greenland .
BMP: LM has investigated the
hydropower potential for the project.
The study is reported in Annex 9 of the
EIA report. This preliminary study of the
hydropower potential is part of the
material available for public hearing. In
the study focus is primarily on the hydro
power potential of Imarsuup Tasia since
this site is the most promising in
connection with the Isua project.
However, the hydro power potential of
Imarsuup Tasia is reserved for Alcoa’s
aluminium project which means that
hydro power from Imarsuup Tasia for
the time being is not an option for LM.
It is BMP’s the opinion that
Departementet for Bolig, Infrastruktur
None
38
energy) can be met through the construction
of new plants and by increasing the water
resource by building tunnels to new
catchment areas.
Since London Mining (the Isua project) is not
the only energy demanding large-scale
project, which is investigating the
(hydropower) potential of the area and since
the potential according to estimates by
Nukissiorfiits are available to meet the energy
requirements of both potential energy
requiring projects (the ALCOA project at
Maniitsoq and London Mining) and to secure
the future energy supply in Nuuk we propose
that an integrated solution is found in
cooperation with Nukissiorfiit, Asiaq and other
partners (companies) with knowledge in this
area.
If some water potentials are not available for
the Isua project the Nukissiorfiits report points
out that an alternative hydropower potential
of c. 65 MW is available in the Isua area.
A further option would be to expand the
hydropower plant at the Buksefjord to 160
MW which would open for offering energy to
for example the Isua project and secure future
energy supply needs in Nuuk. This would
require transmission cable between the
og Trafik (Department of Housing,
Infrastructure and Traffic) should
initiate an additional study of the
possibilities to integrate the energy
supply of potential industrial projects
with the public energy supply. The study
should be coordinated with Nukissiorfiit
and Asiaq.
However, it is BMP’s view that
integrating industrial and public energy
supplies into one publicly owned
company is a very risky model. The
expense for constructing a power plant
probably exceeds 10 million Danish kr.
Such a large amount will make it a very
risky project for a public company.
In Spring 2012 Inatsisartut decided not
to become owner of an aluminium
project (see point 112 in the minutes).
None of the members of Inatsisartut
votes against this decision. Inatsisartuts
Erhvervsudvalg (Business Board) has
expressed that “the board does not
believe that the financial situation
permits even a partly ownership of a
project of this type”.
Without an a agreement with a private
company that has a very long running
39
Buksefjord hydropower plant via Nuuk to the
Isua area. Such an integrated plan would imply
that Nuuk is connected to two supply
networks and that an emergency diesel plant
will no longer be needed.
At present there is only one transmission line
to Nuuk, the one from the Buksefjord plant
and in this situation Nukissiorfiit will have to
expand the diesel powered emergence plant
at Nuuk. An integrated solution will therefore
have large befits for the society and for the
supply security.
When the mine closes the hydropower plant
can supply the industrial development in the
area and supply power to Nuuk.
Nukissiorfiits’ possibility analyses also
highlight the obvious economical benefits of
using hydropower because of the much higher
and fluctuating running costs associated with
diesel.
period there is a danger that a public
company could end up investing a large
amount and has no privat company to
buy the energy. It would be the
Greenland Self Government – and
ultimately the Greenland people – that
would end up with the bill.
12.5 Short Lived Climate Forcers (SLCF)
Burning of fossil fuel result in emission of SO2,
NOx, CO, soot (black carbon) and other air
pollutants (PM). Of particular relevance in an
arctic context are the concentrations of soot.
Soot is a short lived climate forcers, SLCF
Black carbon (BC) is a major component of soot
emitted by incomplete combustion of fuel. BC is the
most efficient atmospheric particulate species at
absorbing visible light. BC is an Arctic haze aerosol
absorbing sunlight with a resultant strong warming
effect in the atmosphere. BC influences cloud
BMP: LM is obliged to follow national and international rules and regulations regarding shipping and pollution in connection with shipping. In addition Greenland Self Government can formulate additional demands and rules
The
terminology
of dust, black
carbon and
particulate
matters will
40
which in spite of its short life has a marked
impact on human induced global heating.
Most soot is transported to the arctic from
countries far away. It should be noted that
that emissions of soot in the arctic has much
larger impact on the human induced heating
of arctic than emissions from other parts of
the world (AMAP, The Impact of Black Carbon
on Arctic Climate, 2011). When soot is
emitted to the atmosphere and deposited on
ice and snow it will absorb light from the sun
and convert the energy to heath. This will
contribute significantly to global heating and
local melting of snow and ice. Although soot in
the atmosphere is short lived (1-4 weeks) its
impact on regional climatic change is large
(around 30% according to UNEP) of the latest
observed heating in the arctic. When soot is
deposited on ice and snow (particularly
reflective surfaces) its “life” (effect) is
extended, since the soot accumulates on the
surface. The effect of soot on the climate (its
ability to increase melting) is strongest in
spring, when the energy from the sun is most
intensive and the snow- and ice cover is
largest. Deposition of soot on for example the
Inland ice will therefore lead to increased
melting.
A discussion of the consequences of soot
formation and reduces the reflectivity (albedo) of
snow and ice when it is deposited, accelerating
melting and earlier opening of sea ice.
BC is recognized as a significant short-lived climate
forcer (SLCF) of particular significance for climate
change in the Arctic. It has a strong warming
potential (albedo feedback, direct atmospheric
warming) but also cooling potential (cloud
interaction).
BC also contributes to the adverse impacts on
human health of PM2.5 (Particulate matter with size
less than 2.5 μm)The health impact of BC is integral
in PM2.5 limit values, which are based on the overall
health risk of fine particulate matter.
Most BC in the Arctic comes from emissions outside
the Arctic.
Due to the relatively short lifetime of BC in the
atmosphere compared to other GHG (Greenhouse
Gasses), and lack of standardized and practical
quantitative models to estimate impact of the
numerous mechanisms involved, it is not possible at
this time to draw quantitative conclusions on the
impact of BC from the Isua project on regional or
global climate.
that must be followed if necessary.
DCE/GN recommend monitoring
possible formation and spread of black
carbon from the combustion of fossil
fuels in power plants, trucks, ships, etc.
be cross
checked
between the
English and
Danish
/Greenlandic
translation.
41
emissions should be included in the EIA.
The soot is mentioned in the EIA in connection
with shipping but the emissions from the main
source burning of 210 million diesel annually
at the project power plants should also be
mentioned.
The discussion of dust, soot and other
particles in the EIA is difficult to understand
because the terminology used diverges.
It is noted with satisfaction that the project
will use arctic diesel (AFD) for the power
plants because of its good characteristics in an
arctic environment. As far as shipping is
concerned it is recommended to use other
fuel types that heavy oil because of the
emissions of pollutants associated with this
type of fuel.
The type of fuel used for shipping will follow the
regulations.
12.6 Other comments
In connection with Naalakkersuisuts reporting
to the UNFCCC (UN’s climate convention) it is
expected that data are provided by the
company (London Mining) and its suppliers for
Greenland’s report as is the case with other
mineral projects in the country.
London Mining is committed to provide all required
data for Naalakkersuisut’s reporting to the UNFCCC.
DCE/GN: Nothing to add.
None
42
13. ICC og WWF
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
13.1 Herewith common hearings responses from
ICC and WWF regarding EIA and SIA for the
London Mining/Isua project are submitted.
None - -
13.2 As announced in September 2012, ICC
Greenland and WWF partnered to focus on
the development of large-scale industry and
public involvement in decisions. Therefore,
we have prepared a joint response regarding
London Mining/lsua project.
Below are our comments to the published
Environmental Impact Assessment (EIA) and
Social Impact Assessment (SIA).
None - None
13.3 1. General comments
This hearing is the first of its kind for a
possible large-scale project in Greenland. ICC
Greenland and WWF have chosen to provide
a joint response to cover as much as possible
of the comprehensive material. Even
through joint effort, we have not been able
to work through the entire hearing material.
There are two separate hearings, a hearing
on Environmental Impact Assessment (EIA)
and a hearing on the Social Impact
This is a matter for the Greenland Government
BMP: The public meetings including the
structure of the meetings will be
evaluated also with focus on the length
of the public hearing phase. The
comments are noted and will be
considered in this process.
None
43
Assessment (SIA). ICC Greenland and WWF
DK therefore consider that the consultation
should be extended for at least 3 weeks.
During the hearing period there has been
held four public meetings, where a number
of relevant questions have been asked, and
there has been a lot of waiting on some of
the questions which could clarify some of
the misunderstandings which may have
arisen in the process.
Alongside this hearing, there have been
other relevant hearings; two Strategic
Environmental Assessment (SEA) for
offshore oil license areas, changing the
Mineral Resources Act, and the bill for
building and construction projects of large
scale projects. The latter two are direct
prerequisites for London Mining iron mining
project and it can thus be argued that this
hearing should be after a possible adoption
of the two bills.
13.4 2. Alternative energy sources-hydropower
versus fossil fuel
The Government of Greenland has for more
than a decade invested purposeful in the
development of green energy, especially
hydropower. And Naalakkersuisut states in
the coalition agreement of 2009 that "a
This is mainly a matter for the Greenland
Government. It should, however, be noted that
London Mining does not have the right to use the
water resource in the project area for hydro power
(this right belongs to other organizations). In spite of
BMP: Hydropower viewpoint is noted.
According to the BMP guidelines for
preparing an Environmental Impact
Assessment (EIA) Report for mineral
exploitation in Greenland, energy
demands (energy sources and supply)
None
44
Greenland, which primarily derives its
energy from green energy is the
fundamental vision".
The long-term investment in hydropower is
good for both the economy and the
environment. Hydropower replaces fossil
fuels, limiting emissions of C02 and harmful
particles into the air, and after a few years of
operation the investment has paid for itself.
Investments in renewable energy have been
highlighted in the international negotiations
under the Climate Convention. Thus back in
2009 Naalakkersuisut established that in the
post-Kyoto period the emissions of C02 in
civil society will be reduced by 5 per cent;
that it will continue to invest in renewable
energy and the need to develop mining
activities and major emitting facility in
accordance with international standards and
principles of sustainable development,
including Best Available Techniques (BAT)
and Best Environmental Practices (BEP) (see
the President of Naalakkersuisut's letter to
the then Minister for Climate and Energy
Lykke Friis, November 24, 2009, with
attachment of Greenlands obligations
concerning reduction of greenhouse gas
emissions in the period 2013-2020).
this, London Mining requested the International
Engineering firm SNC-Lavalin to study if hydropower
could be used on an viable basis for the Isua project.
This study concluded that the secure hydropower
potential is 120 MW. This is around 80% of the
power needed for the Isua project. A decision to use
hydropower also involves financial analyses.
Based on a financial model developed by SNC-
Lavalin, the increased capital expenses combined
with the production delays caused by the estimated
7 years construction schedule for the hydropower
dams and transmission lines will make the project
not financially possible.
has to be described including a detailed
description of the hydrology. If
hydropower due to economical or
technical reasons is not feasible, this
has to be documented. The
documentation makes it possible to
decide upon a complete material.
The Greenland Government is
supporting the companies in finding the
best hydropower solution for all the
relevant mineral projects. It is also a
requirement in the guidelines that
hydropower has to be considered as
part of the project. The hydropower
potential has to be considered with
respect to the already excisting
hydropower scenario in the area.
DCE/GN: Nothing to add.
45
Seen in this light ICC and the WWF find it
without vision that there now is an energy
consuming iron ore project on the drawing
board, where hydropower is not an integral
part of the project.
Renewable energy should be part of
the solution. Establishment of
hydropower will be in the
Greenlandic community interest,
also because it will reduce the
footprint of the project.
Annex 9 for the EIA report "Preliminary
study of the possibilities of developing
hydropower", according to SNC-Lavalin, who
has prepared the report, a preliminary study
and the results presented have been
achieved as a result of a desk job, which
further is based on incomplete data and
information from previous studies. By
introduction, it appears that the study is
partly based on a limited set of hydrological
field observation and topographical
information available from the following
studies and supported by hypotheses based
on SNC-Lavalins experience from similar
projects under similar conditions. It is also
emphasized that the findings can only be
validated by further investigation and a
more detailed hydrological assessment and
46
field work.
We believe that the importance of
hydropower versus fossil fuel,
however, is too great and the
consequences too many for the
decision to be taken on an
incomplete material.
There should be a detailed and
comprehensive study of the
possibilities for integrating
hydropower in London Mining Isua
project. If it is estimated that the
potential to use hydroelectric power
is present, it should be a requirement
that the solution is chosen.
The potential of two hydropower plans to
meet the energy needs of the operation of
the mine in the Isua project is assessed in
the report. It is concluded that a hydropower
solution based on the Imarsuaq Scheme is
the preferred solution to achieve the
required installation capacity of 120 MW in
the Isua project, but hydropower is not a
real alternative. At least not because a
construction period will be too long
compared to operational period of the mine
project.
Table 4.9 p 93 of the EIA report of August
47
2012 shows ratios for the different energy
solutions. With the use of fossil fuels in Isua
project, Greenland's annual CO2 emissions
from fossil fuel increases with 47 per cent,
while a project based on hydropower from
Imarssuaq will lead to a limited increase in
CO2 emissions of just 2 per cent. If the
estimated investment for the construction
and operation for 15 years is looked upon it
amounts to about 4.7 billion USD for a
solution based on fossil fuels. The
investment in Imarssuaq hydropower plan
estimated at approx. 1.3 billion USD. This is a
difference of approx. 3.4 billion USD for
water power alternative. This difference will
further grow if the life of the project is
extended to 20 or 30 years.
In addition to reducing CO2
emissions and pollutant particles
into the air, a hydroelectric plant
could operate for decades and thus
be of great value to the community
in Greenland, also after mine end.
In the public debate, it has been argued that
the area's hydropower potential is reserved
for the Alcoa aluminum project at Maniitsoq.
This situation is not for the benefit of the
Greenlandic society and Naalakkersuisut
should seek a clarification. Naalakkersuisut
48
should also develop visions for future
industrial development in Greenland.
Naalakkersuisut should develop an
overall strategy for the development
of large-scale industry based on
renewable energy. It should be
facing international companies and
investors emphasize that green
energy is part of the solution.
13.5 3. Caribou
The caribou will undoubtedly be more or less disturbed by the Isua project and the various phases, and disturbances cannot be avoided.
It is assented to the recommendation of the
EIA report p. 154 and the proposal that an
environmental employee participate in the
planning of the construction work to ensure
that the disruption of caribou is minimized
and at the same time that works be avoided
in specific areas in the calving time (15/5 -
30/6 ).
However, it should be a requirement
that such a measure be taken, as it is
a requirement to hire an
environmental officer as proposed,
together with a representative of the
hunters identified in cooperation
Comment noted for future detailed planning and
work on monitoring program in co-operation with
the Greenland authorities.
BMP: Regulation related to monitoring,
reporting and an environmental
employee can be put into the final
government approval. Some of the
issues can also be a part of the Impact
Benefit Agreement.
DCE/GN expects to be included in the
company proposed cooperation on
planing the monitoring of project
impacts on the reindeer population.
None
49
with KNAPK.
It is also recommended in the report that a
3-4 - year monitoring program is established
with the primary objective to investigate
whether the build caribou-ramps work as
intended and thus ensure that the animals
can move freely between winter, calving and
summer areas. It is important that ramps
work as intended as the caribous otherwise
become completely unable to move freely
between areas north and south of the study
area. The proposed monitoring program
would further collect information and
provide new knowledge about the
Greenland caribou behavior, which could
subsequently be used in conjunction with
other projects.
It should be a requirement for the
Isua project that such a monitoring
program is established, both for the
animals in the area, but also as a
basis for knowledge and capacity
building in Greenland.
Caribou hunting in the study area
will be forced into other areas. The
monitoring program should also
examine how hunting pressure on
caribou will change and how the
population of caribou react to such a
Comment noted for future detailed planning and
work on monitoring program in co-operation with
the Greenland authorities.
Comment noted for future detailed planning and
work on monitoring program in co-operation with
the Greenland authorities.
50
change. If hunting pressure is
increased in smaller and more
concentrated areas it should be
ensured that the animals can
withstand such pressure. Possibly
with management actions to follow.
In connection with the disturbance of
caribou population, we will mention the ICC
Greenland during the hearing regarding the
expansion of London Mining's exploration
license in March 2012, has required a change
of the alignment. Section 4.11.10 mentioned
briefly that a change in routing including to
increase the path length, involve more
extensive construction work and have
greater adverse visual effects, these things
mentioned without further explanation.
The selection of the proposed routing for the road-
pipeline corridor has balanced engineering as well as
environmental issues and concerns. During the
process other routes were considered but were
rejected because they were either not technically
feasible or because they were feared to lead to
larger impact on wildlife.
13.6 4. Whale Collision and noise from traffic
Collision of humpback whales in
Godthåbsfjord can cause damage to the
animal or, in the worst cases, death. It is
described in Annex 3, Marine mammals and
birds that ships from the Isua project will run
at low speed, thereby reducing the risk of
collision with whales significantly. The risk of
collision with whales is present whether
sailing in the Godthåbsfjord or other places.
The expected navigational speed of the ships as they
sail through the Godthåbsfjord system will be low
and likely to be in the vicinity of the here mentioned
10-11 knots.
DCE/GN recommends implementation
of surveillance of whale responses to
maritime transport, and that in this
context, particular attention is paid to
the importance of ship speeds
None
51
It should be a requirement that the
ships of the project sail with a max
speed of 10-11 knots in
Godthåbsfjord in order to reduce the
risk of collision with whales.
The Godthåbsfjord is an important feeding
area for humpback whales which enter each
year to the fjord. Noise from traffic can
cause temporary displacements of
humpback whales from these important
habitats.
We refer to comments from DCE /
GNIR for EIA for Isua project of 13.
August 2012, which propose the
establishment of a monitoring
program to determine the project's
potential effects on whales in
Godthåbsfjord.
Comment noted for future detailed planning and
work on monitoring programme.
13.7 5. Navigational Safety
The Annex Study of Navigational Safety (after Requirements and Guidelines from the Danish Maritime Authority (DMA) per January 10, 2011) to the EIA report aims to present a study of navigational safety in the Isua project. Such studies have since 2011 been a requirement set by an agreement between the BMP and the Danish Maritime Authority. The report submitted to the public via Naalakkersuisut's hearing portal
The Navigational Safety Investigation is not part of
the EIA, but was conducted as per Danish Maritime
Authority (DMA) requirements and guidelines dated
10 January 2011. The Danish translation of the
Navigational Safety study has been checked again,
and while some minor mistakes have been
corrected, it is felt that the translation is true to the
original.
BMP: Requirements on following the
IMO guidelines and recommendations
can be put into the final government
approvals.
DCE/GN: Nothing to add.
None
52
on the website is stuffed with linguistic errors and you can ask whether it is a proofread report or on an unfinished version by mistake has been posted on the website. The report, however, form the basis for our hearings answer on Sailing Safety section hereunder.
The port of Taseraarssuk will likely be called
at of several different size classes of ships.
Due to the high load factor at a single berth
in the Isua project it is decided to build a
second berth to handle import cargo. In the
report's Table 7-5, page 36, appears tonnage
and dimensions for the types of bulk carriers
expected to be used in the Isua project. The
smallest ships are 65.000 deadweight
tonnages (DWT), with a length about 245 m,
width 35 m and depth of 12 m, while the
largest is at 250.000 DWT, 330m length, 57
m wide and 18 m in depth. The expected
number of calls per month will be between 9
and 11 ships.
Ships to serve in polar waters are
recommended to follow the In ternational
Maritime Organization (IMO) Guidelines for
navigation in polar waters (2009). The
Greenlandic waters are defined as polar. In
reports it can be read that bulk carriers to
lsua project will not be ice-classified. The
reason for this is that they are mostly will
The conclusions of the NSI are in agreement with
this comment; it is a recommendation of the NSI
that local navigators experienced with navigation in
Greenland polar waters will assist bulk-carriers in
their course along the fjord.
There are only very few ice class large bulk carriers
and they are in the Handimax and Panamax
categories (smaller than 70,000 DWT). Such ships
are too small for the Isua project shipping
requirements. For the Isua project, the operation
plan and economics of the project are designed
based on Capesize (180,000 DWT) or larger (250,000
DWT) type of bulk carriers. There are no known
carriers in these sizes that are ice classed.
The shipping of the Isua iron ore concentrate will
likely be concentrated to qualified shipping
companies who own and/or operate chartered bulk
carriers. At this point, London Mining has no
agreement with any shipping companies for
exporting the iron ore concentrate and importing of
consumables.
As to shipping companies that provide chartered
bulk carriers, it is required to follow as applicable
the International Maritime Guidelines (IMO) –
Guidelines for Ships Operating in Polar Waters, and
to follow as well Greenland orders, applicable
Danish maritime regulations, and other applicable
53
sail in polar waters which are not covered
with ice. All other vessels, including fuel
ships and tugs, however, will be of an
appropriate ice-class. Simultaneously IMO
guidelines recommend that all vessels in ice-
covered polar waters have at least one ice
navigator.
IMO guidelines are
recommendations, not requirements
(as stated in the EIA report), ICC
Greenland and WWF believe it
should be a requirement for Isua
project that these recommendations
are followed. This is also consistent
with the intentions of using BAT.
Will LM elaborate reasons why bulk
carriers are not ice-classified, despite
that parts of the Godthåbsfjord
annually is coated in solid ice to a
thickness of up to/60 cm and
icebergs calves from nearby
glaciers? Does LM believe that it is
safe to let bulk carriers that are not
ice classified service Isua project?
The vessels are expected to meet IMO
elements of the guidance lines which include
navigation equipment, livestock and
environmental protection and preparedness.
conventions related to navigation, environment,
health and safety.
The navigational safety study indicated that there
should be no problem with appropriate
management assisted with the ice classed tugs and
with low travel speed.
The comments that the IMO guidelines are
recommendations not requirements are
acknowledged. However, they do contain a number
of requirements that should be fulfilled if the
guidelines are to be considered followed.
According to DMI’s report Statistics of Ice Conditions
in Northern Godthåbsfjord, dated January 2010, the
parts of the fjord than normally develop fast ice are
not along the proposed shipping route. The calving
of glacial ice are mostly in the forms of growlers or
bergy bits, slow speed, large sturdy ships, ice
scouting.
Ice thickness of up to 60 cm in Godthåbsfjord is
limited to a short period only and to a very short
distance of a few kilometres along the route to the
port. The conclusions for the shipping of Isua iron
concentrate are based on a careful assessment of
ice conditions in Godthåbsfjord where London
Mining requested the service of the Danish
Meteorological Institute (DMI) for a study of ice
conditions in the northern part of Godthåbsfjord;
London Mining also requested maritime specialists
54
from BFS Engineer SNC-Lavelin to review the data
from GEUS and navigation information from Royal
Arctic Lines. The key conclusions from these studies
are presented as part of the Navigational safety
Investigation and they are reported in connection
with this comment: the studies “show the maximum
extent of sea ice coverage, as determined by satellite
imagery, is about 10 km of sea ice at the head of
Qugssuk Bay. Under this condition, ships
arriving/departing from Taseraarssuk port site
would need to transit about 6 km of sea ice. In the
context of ship operations, this sea ice condition
would be of a limited duration, possibly 3 or 4
weeks”. The studies also conclude: “It is considered
extremely unlikely that even a non ice class ship will
suffer any damages when moving through first year
ice of 50 to 60 cm, providing it is following
appropriate ice navigation procedures”. The
appropriate ice navigation procedures are also
presented in the studies for the shipping of Isua iron
concentrate, including ice class tug boats to assist
bulk carriers navigation for the short occasional
transit of 6 km in sea ice, presence on the bulk
carrier of experienced navigators, ice monitoring
systems and others.
13.8
There are no charts of the inner parts of
Godthåbsfjord. Until planned hydrographical
studies of Godthåbsfjord from Nuuk to
The conclusions of the NSI are in agreement with
this comment: hydrographic surveys and nautical
maps need to be completed. This work is to be
-
None
55
Taseraarssuk is completed (expected to be
performed by the Maritime Safety
Administration and Survey and Cadastre
Authority), the navigation to and from Nuuk
depend on available maps and traditional
maritime navigation techniques. The only
map, used in the report on navigational
safety is chart 38541fra USGS National
Agency and Mapping Agency, covering the
entrance to the Godthåbsfjord.
Unfortunately, it is not unusual for ships to
run aground in Greenland coastal areas.
Recently the passenger ship SarfaqIttuk ran
aground just outside the port of Qaqortoq
(d. 10/10). Godthåbsfjord has never before
been serviced by such large vessels that are
expected to operate the Isua project and
ships of this magnitude have never before
been fully engaged by Taseraarsuuk.
It should be a requirement that there
is an updated hydrographic survey of
the fjord and relevant charts are
available for use before ships begin
to operate Isua project.
According to the report a middle fairway
buoy 1-2 nautical miles from the port of
Taseraarsuuk should be established. This will
serve as boarding station for a pilot. It is not
carried out in a next step before operation of the
mine starts and under the guidance and
requirements of DMA and Danish Hydrographic
agency. It is understood that the Danish
Hydrographic Office -National Survey and Cadastre,
Greenland has undertaken hydrographic survey
work in part of the Godthabsfjord, between Nuuk to
the Isua Port. It is also understood that Danish
Hydrographic Office is to prepare and issue nautical
charts for some areas of Godthabsfjord.
Once this information is made available, it is the
plan to review this information and then, to work
with DMA and the Danish Hydrographic Office-
National Survey and Cadastre, Greenland in order to
establish clearly those areas of Godthabsfjord where
more hydrographic surveys need to be completed
by London Mining and to prepare additional nautical
charts where needed. Inputs and advices from
Danish Hydrographic Office and from Danish
Maritime Authority will be needed in order to
execute this work in compliance with the methods
and scope expected by the Authorities.
During the construction period the size of ships
servicing the constructions sites are expected to be
significantly smaller than the large bulk carriers
needed during mine operation. The DMA
requirements apply for navigation during operation.
Due to the length of the construction period, it is
expected that such cartography and hydrographic
56
clear from the report on which route the
pilot will be on board and whether it is a
requirement that ships must have a pilot on
board.
LM should indicate whether all (or
which) ships to and from the Isua
project is expected to have a pilot on
board and on which route the pilot in
this case is on board?
surveying will be completed by the time production
begins, and larger bulk carriers can be expected.
The need of a local pilot, during which period for
such a need and where, if such a need is required,
the pilot should be on board will be assessed
carefully together with the Greenlandic authorities,
DMA and the shipping companies prior to the start
of the operation. The relevant governmental
regulations will be strictly followed.
13.9 The introduction of non-native species into
new marine areas in ships' ballast water is
one of the biggest ecological threats to the
world's oceans (p. 68). It is likely that in the
sensitive Arctic ecosystem, which the
Godthåbsfjord is part of, the introduction of
such alien species have disastrous ecological
consequences.
It should be a requirement for
vessels calling at the port of
Taseraarsuk that they follow the
rules of the International Convention
for the Control and Management of
Ships' Ballast Water and sediments
(BWM) to minimize the risk of
introduction of non-native species.
The BWM has not yet been ratified by Greenland,
however it should be noted that the Government of
Greenland (BMP) as a reply to a similar question at
the 3th public meeting made it clear that it will
“require that ships to the mine follow the
convention”.
This is also reflected in the EIA report (sections
0.7.8, 6.2.6 and 7.2.9) and Annex 3 (section 6.3.9).
DCE/GN: Nothing to add. None
13.10 The report Survey of navigational safety
mentions on page 72 that Orbicons report
on the assessment of risks, impacts and
The Navigational Safety Investigation is not part of
the EIA, but was conducted as per DMA
DCE/GN: Nothing to add. None
57
mitigation measures of accidental spills of
hydrocarbons is attached to the study of
navigational safety as Annex H. A few
sentences below it appear that the main
conclusions from Appendix H are reported
in this report. It is not clear whether Annex
H and Appendix H cowers the same
document, even if this is to be assumed.
This document is not attached to the report
on navigational safety, nor is it to be found
in the Naalakkersuisut's consultation portal
on the website. So important a document
should be publicly accessible and easy to
locate.
From section 10.5 'Assessment of risks and
possible effects of hydrocarbon spills on
because of shipping during the operational
phase' it appears that significant amounts of
fuel and chemicals will be transported to
Taseraarsuk each year in large tankers and
other vessels. The report estimates that the
risk of oil spills and chemical accidents is
low. But if such an accident occurs the
consequences for life in the fjord can be very
severe and restoration of livelihoods can be
long-term. The report mentions that the
precautions and preventive measures should
be implemented and that it is important to
have effective contingency plans in place.
requirements and guidelines dated 10 January 2011.
However, Appendix H mentioned internally in the
Navigational Safety Investigation is Annex 6 to the
main EIA, which is available for download on the
hearing portal.
Delivery of artic diesel to Isua port will be by the
same types of ships that currently navigate in
Greenland waters for supplying fuel to Greenland
towns and settlements.
Shipping and maritime regulations taken into
58
What international and national
regulations, does the LM take into
account? The following international
agreements relevant to safety in
Greenland waters: SOLAS, MARPOL
and the OSPAR Convention and the
London Convention and OPRC 90.
Although the OSPAR Convention is
not directly applicable to the west
coast, then OSPAR standards and
requirements are still considered
good practice.
If a hydroelectric power station is
established in connection with the
Isua project large quantities of fuel
transported through the fjord will be
minimized considerably, which we
consider to be desirable and an aim
to be pursued.
consideration are noted in the EIA, section 2.3.
Comment on OSPAR noted for future negotiations
between LM and BMP/DMA.
See also answer in section 12.4.
13.11 6. Fuels for ships Ship traffic to and from the lsua project will result in increased emissions from fuel combustion in the Godthåbsfjord. Primary emissions are carbon black (fine soot particles of carbon and other substances), NOx, S02, particles of organic matter and C02. The particles are considered in the report to cause a regional pollution rather than a local pollution.
Issues regarding Heavy Fuel Oil (HFO), emissions and
spills are treated in the EIA section 7.1.8, Annex 3,
section 3.8, Annex 6, sections 5.1, 7 and 8.3
The issue is covered in the EIA section 7.1.8, Annex
6, section 7.1
The shipping of iron ore is an established large
industry in the world and London Mining’s
BMP: Requirements related to
light/heavy fuel will be set in the final
government approvals.
DCE/GN recommend that the company
be required to use light fuel oil in
accordance with the Polar Code, which
is expected to be adopted by the
None
59
Analysis and conclusions in the report are
made on the basis of current Greenlandic
and Danish regulations for shipping and
include the assumption that heavy fuel oil
will be used as fuel in ships. IMO has
recently tightened the rules so that it is no
longer allowed to use the heavy fuel oil in
Antarctica. Similar tightening of shipping in
the Arctic are on the way, which would
mean smaller amounts of the burning gases
and thus less impact on the environment.
This will also reduce the release of soot from
any burning, something which the Arctic
Council recently has identified as an
important area to reduce.
The light fuel oil should take
precedence over the heavy as fuel
for ships Isua project, by which
Greenland is pioneer in the Arctic for
this approach. This should also apply
to third-party vessels associated with
the project.
operation will not be expected to be different with
the established model. Shipping in Greenland
waters will follow the regulations.
The shipping of the Isua iron ore concentrate will
likely be contracted to qualified shipping companies
who own and/or operate chartered bulk carriers. At
this point, London Mining has no agreement with
any shipping companies for exporting the iron ore
concentrate and for importing of consumables. The
qualified shipping companies that operate in Polar
Waters are aware of the applicable rules and
guidelines such as the International Maritime
Guidelines (IMO) Guidelines for Ships Operating in
Polar Waters, as well Greenland orders, applicable
Danish maritime regulations, and other applicable
conventions related to navigation, environment,
health & safety. These shipping companies are
expected to comply with legal requirements.
International Maritime Organization
(IMO).
13.12 7. Waste water treatment and chemical spills
Minimum levels of chemicals and water treatment should follow the European standards, or even stricter requirements, as these are operated in a vulnerable Arctic environment. An environment which may
BMP has established guidelines for preparing an
Environmental Impact Assessment (EIA), in which
are presented the GWQG (Greenland Water Quality
Guidelines). These are based on standards from
several sources, including the EU, USA and Canada.
BMP: Discharge to the nature has to
follow international best practice and
the requirements in the government
approvals has to be set after guidance
of DCE and GN.
None
60
have more difficulty recovering from stress and disasters than is the case for other environments. ICC Greenland and WWF endorses DCE / GINR 's comments on eco-toxicological tests on effluent pipeline and tailings, including continuous measurements and the requirement for complete details on the content of reagents and chemicals.
It is mentioned in the material that pipelines
will be equipped with temperature-and
pressure-sensitive control systems to detect
leakage. Experience with similar systems in
Alaska is mentioned, but experience from
ICC Alaska says that technical systems as
these are not infallible and those emissions
have gone unnoticed due to the lack of
physical checks. ICC Greenland and WWF
recommend that the pipelines be checked at
regular intervals regardless of whether
control systems report irregularities or not.
Following the comments by DCE/GINR, it is planned
in the EIA that eco-toxicity testing will be conducted
and the monitoring plan presented in the EIA already
covers the recommendations in this
comment.Comment noted for future detailed
planning and work on maintenance routines and
surveys.
13.13 8. Contingency
Contingency plans must of course follow the
prescribed national and international
standards and recommendations. In
addition, contingency plans must follow the
principles of openness and transparency
with the bare minimum of information
crossed out, so plans can be evaluated by
independent third parties. Denmark has
Comment noted for future work on detailed
contingency planning.
-
None
61
joined the Aarhus Convention, and although
Greenland so far is excepted, ICC Greenland
and WWF recommend that the Convention
is followed as good practice.
13.14 9. Closure
It is very important to focus on
environmental, social and economic impacts
of a mine closure. While investment may
bear some temporary economic
consequences, the environment and society
would bear permanent consequences.
Internationally, there are differences in the
requirements for decommissioning
procedures, but when, as here, "best
practices" are aimed at one should meet the
most stringent existing rules, for example,
Ecuador requires plans for water
purification, revegetation, treatment of
residues and management of flora and fauna
(Garcia, D.H. 2008. Overview of International
Mine Closure Guidelines. American Institute
of Professional Geologistys, s 1-9)*.
While explaining the mitigating measures
during decommissioning in relation to the
environment, an account of mitigating
measures in relation to economic and
societal consequences of a shutdown is
lacking for example by job losses within a
A closure plan is prepared by London Mining for the
ISUA project. The closure plan has followed the
general practice in northern regions and is aiming at
to return, as close as practical, the conditions to the
original conditions. The expected management of
the mine personnel at closure will be discussed in
the IBA.However, when the mine is closed, it is
inevitable that there will be losses of jobs and
revenues.
DCE/GN: Nothing to add
62
short period of time, and loss of income.
13.15 Consultation response on. London Mining /
Isua project in the light of SIA Report
Grontmij A / S, July 2012
13.16 General Comments
The report Social Impact Assessment for lsua
iron ore projects for London Mining
Greenland A / S provides a comprehensive
description of the Greenlandic society with a
focus on Nuuk and Kapisillit. Generally, it is a
very comprehensive report that describes
many different aspects of the Greenlandic
society, including population composition,
education, working life but also describes
civil society.
The SIA report is written in a language that is
easily understandable but one could have
worked more with the structure of the
report to promote readability. The reports
proportion is 327 pages, but you have to get
to page 118 before you are presented with
the first real analysis of the project's social
sustainability. And as reader you have to get
to page 191 before a plan for managing the
impact of the project is presented. The initial
description of the Greenlandic society could
have the shortened considerably and could
The format of the report is following the BMP
guidelines.
BMP: Within the nearest future the
BMP will be working on an updated SIA
guideline. It has to be emphasized that
the BMP guideline is a guideline and
not a law text.
DCE/GN: No environmental aspect.
None
63
be added to the report as appendices.
The report provides a picture of many
aspects of the Greenlandic society, but is
marred by an unclear and varying use of
terminology and spellings. In addition, the
report have a few faults , which should have
been addressed by the audit of the report in
June 2012.
The following are comments on a range of
sections of the VSB report.
13.17 4. SIA methodology
The method behind the study is presented in
just 4 pages where the focus is on describing
the collection of the data underlying the
report. For the reader it is not clear how the
analysis is performed and how to arrive at
the conclusions presented in Section 6
The comment will be taken into account. Further
information will be provided on the methodology
and criteria used for evaluating and assessing
impacts.
DCE/GN: No environmental aspect.
The section
on the
methodlogy
will be
expanded.
13.18 5. Social and economic background
conditions
Purpose of this section is to give a broad
introduction to the community, including
demographics, economy and society
building. The section contains a large
amount of information and one could have
easily have shortened the section slightly
and attached some of the figures in an
The comment on the small number of ambiguities
and errors will be taken into account.
DCE/GN: No environmental aspect.
The
comment on
the small
number of
ambiguities
and errors
will be taken
64
appendix to the report. Throughout the
section, there are a small number of
ambiguities and errors one should have
directed the review in the summer of 2012.
The description of the legislative and
executive powers is unclear and
there is no consistency in the use of
terminology. After Self-Government
Act the legilative power is
Inatsisartut and the executive
Naalakkersuisut, but text refers to
both "government" and
"government chairman".
In the same section is an overview of
civil society organizations. This lack
Nuup Kangerluata Ikinngutai / Nuuk
fjord Friends, that is very active in
the debate on just London Mining
project.
In the section on public health in
Greenland is stated, in a section on
crime and violence (section 5.7.3.4),
inaccurate information on
organization of the judicial system in
Greenland. According to the Court
Administration the justice system in
Greenland consists of 18 circuit
courts, the Court of Greenland and
Greenland High Court.
into
account.
The two last
paragraphs
in section
65
Section about the sale of fish and
capture by the board is written
before January 2011. The text
should be reviewed prior to
publication.
The SIA report also contains a section on the
Greenlandic people's relations with the
international community (5.8.3). The section
focuses on a very relevant issue-reliance on
external labor and the consequences this has
for both wage levels, capacity building etc. In
the SIA report this is described a little
simplistic, as a struggle against the influx of
foreign labor. Thus you get expressed that
the Greenlandic society wants to close itself
from the surrounding world. Rather than a
battle there is talk about a challenge in
relation to training and qualification of the
labor force in Greenland, which the
Greenlandic politicians bring into focus.
The two last paragraphs in section 5.8.3 will be
rewritten in order to emphasizes the challenges for
Greenland in relation to training and qualification of
the labor force in Greenland, which the Greenlandic
politicians bring into focus.
5.8.3 will be
rewriting in
order to
emphasizes
the
challenges
for
Greenland in
relation to
training and
qualification
of the labor
force in
Greenland,
which the
Greenlandic
politicians
bring into
focus.
13.19 6. Social sustainability assessment
Economy and employment.
The area of economy and employment are
one of the areas where the VSB report
indicates that the project will have major
benefits and opportunities for the
Greenlandic society.
A IBA will be negotiated and agreed between
Greenland Government, Kommuneqarfik
Sermersooq and London Mining. In the IBA, the
details of the employment, recruitment and
retention strategy will be established.
Impact on traditional livelihoods:
The concern of local hunters and society in general
DCE/GN: No environmental aspect.
Recomendati
ons on
coordination
with KNAPK
will be
incorporated
in the SIA.
66
During the construction phase is expected
that less than 10 per cent will get jobs
directly related to the project, while the
operational phase operates with a spread of
20-55 per cent local labor. The section
contains suggestions for how London Mining
can maximize the use of local labor. Much
emphasis is placed on initiatives to
strengthen recruitment to the company, but
also develop strategies for retaining
employees.
For the Greenlandic society, it is essential to
try and maximize the use of local labor, but
just as much to care to invite Greenland
enterprises to participate in part enterprises
of the project. A number of proposals are
outlined in the report, but it is crucial that
you make measurable requirements to do so
also.
The impact on traditional livelihoods in both
construction and operational phases is
assessed in SSA report as low. The
assessment is based on the assumption that
commercial and recreational hunters will
search for new areas where there are fewer
disturbances of wildlife. Yet the local hunters
express major concern for the consequences
was seriously taken into account during the
assessment. The areas used for caribou hunting,
fishing arctic char, picking of berries and seal
hunting, has been identified and mapped for both
commercial and recreational hunters (the majority
of them not expected to be directly impacted by the
project), including amount of produce, number of
visits a year, how much is used for self consumption
and how much is sold, etc. 49 commercial hunters
(36% of total), 208 recreational hunters (22% of
total) and 24 households in Kapisilliit (100%) were
interviewed. All these factors were taken into
account, as well as the concerns expressed. It has to
be noted that the assessment is also based on the
expected low impact on caribous according to the
EIA. Therefore deviations on the expected impact in
wildlife will also have consequences for traditional
livelihoods and monitoring is essential for identify
changes and corrective measures.
Recommendation on Involvement of KNAPK in
monitoring of wildlife will be incorporated in the
benefit and impact plan and the monitoring plan.
Indicators of impact on well-being of hunters and
household economy related to traditional livelihood
will be integrated on the monitoring plan.
Indicators of
impacts on
traditional
livelihood
and
associated
wellbeing of
hunters and
their
households
will be
incorporated
to the
monitoring
plan.
67
of iron mine for their use of the area. It is a
relevant concern, as no security is that the
profits of the new hunting areas will be the
same as in the area that is now disturbed by
the project. And there is no assessment of
the long-term consequences of disturbances
of the hunt.
It is crucial to establish a thorough
monitoring of wildlife in the area, and that
fishermen and hunters are invited to
participate as much as possible in this work.
13.20 Public services and development plans.
If realized, it will according to the VSB report
create a significant pressure on public
services in Nuuk, including increased
pressure on the administration, an increased
need for housing and the need to expand
capacity for handling the waste. In
cooperation with the Municipality of
Sermersooq one should also look at
wastewater issues, including the capacity of
the existing sewer system as well as
opportunities to establish wastewater
treatment before it is discharge into the
fjord and bay.
In addition, it is noted that SSA report's
section on public services and development
Impact on Public services and development plans
was assessed, among others, during a workshop on
consequences of demographic change, with the
participation of local authorities of various areas and
local social and health experts. The result of the
workshop indicate that negative impacts of
increased immigration (permanent residents in
Nuuk) would only start to be experienced with
about 50-75 families and 100 single workers. The
most critical aspect is related to availability and
potential pressure on price of housing. Impact of 150
new households in Nuuk regarding wastewater and
waste was not evaluated. Demand of daycare
centers and school was not identified as a critical
issue by local experts. On the other hand, business
opportunities related to private day care and
DCE/GN: No environmental aspect.
None
68
plans do not address the expected impacts
of the project on the city's day-care centers,
schools, etc.
international schooling were identified as business
opportunities.
However, the Isua Mine is a remote site and a
privately operated site. It is located about 150 km
from Nuuk and there is no public transportation
between Nuuk and the site. During construction
phase, all foreigners workers will stay at the camps
(either at the mine site or at the harbour). Very
limited demand for housing is expected during this
period, mainly management staff.
The same applies for operations: the vast majority of
workers are expected to work on the basis of
rotations, this is being transported back and forward
to their place of residence, (for example 3 weeks in,
2 weeks off) within Greenland or outside. A worker
at Isua does not expect or is required to be based in
Nuuk. It may nevertheless be possible that some
would choose to move to Nuuk, both direct workers
or because of business opportunities. International
workers with children in school age may prefer to
have residence in cities with international schools
outside Greenland.
69
14. Flemming Hybholt
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
14.1 The rationale behind hydropower for Isua
mine project
There is a great need for electricity and
adequate hydropower resources available.
According to available scenario descriptions
there are very large economic advantages of
the use of hydropower, since the alternative
is a new diesel generator plant.
The scenario descriptions must of course
eventually be replaced by thorough and
documented financial calculations.
Regarding London Mining’s response to suggestions
about hydropower, see answer to question number
5.1. and 5.2.
Furthermore, additional explanations are presented
in answers to questions raised at the 3rd public
hearing meeting on 24th September (cf. answer no.
7-9; 15: 31-34).
-
None
14.2 Basis
The electricity demand seems to be
uncertain according to the brief summary of
the "Bankable Feasibility Study" of February
2012 as a correction to a more detailed
material in the "Scoping Study Report" of
February 2011. An initial assessment based
on a total cost of $ 46 per. tons of
concentrate corresponds to electricity costs
Please confer response to question 5.1 and 5.2.
-
None
70
of $ 24 per. ton, resulting in a total
consumption of 100 kWh / ton or a total of
1.5 billion. Kwh.
In the dossier is expected an electricity
consumption of 1.1 billion kwh.
Issues related to CO2 emissions must also be
part of the EIA. A consumption of 1.1 billion
kwh hydropower will save the environment
from emissions of 550,000 tons of CO2 per
year.
The economics related to electricity supply
can be derived from the economic
conditions and general knowledge about the
cost of electricity. The investment in a
hydropower plant at Imarsuup Isua incl.
transmission lines with a capacity of approx.
150 mw is estimated at 2.5 billion DKK. The
investment in diesel power plants of 150 mw
is estimated at 1 billion DKK. In addition,
there will be investments to in fuel systems
and tanks of 100 million $ which equals to
0.5 billion DKK.
14.3 Hydropower potential
In the area between Nuuk and Sisimiut there
hydropower potential which is enough to
Please confer response to question 5.1 and 5.2
-
None
71
supply an aluminum smelter project and the
Isua project. The most detailed material
about the hydropower potentials in the area
is probably at Greenland Development,
supplemented with material in Nukissiorfiit.
The hydropower supplied to Isua mining
project must be expected also to be able to
act as back-up for a coming aluminum
smelter project which is critically depended
on power to shot down in case of a if the
primary supply drops out to avoid damage to
the plant and consequent following
significant costs.
For Isua mining project a drop out of
electricity supply will only cause production
losses, which is in the order of 20 million.
DKK per. days.
14.4 Ownership and financing
It would probably be most convenient to
combine the electricity supply to the Isua
project and aluminum smelter in Manitsoq.
In this way no specific hydropower plant
should be allocated to the Isua project.
Please confer response to question 5.1 and 5.2.
BMP: There are substantial financial
expenditures related to a hydropower
facility. The suggestion is though noted.
None
72
Supply for Isua will conveniently be
established as a first phase of the overall
system and based on Imarsuup Isua. The
economic scope will be of the same
magnitude, also in a situation where the
aluminum smelter is not established.
The funding must be based on a very large
contribution from the Isua mine - equivalent
to the saved capital costs for the mine,
which can be estimated to at 1 billion. DKK.
In addition, it will be reasonable with a down
payment, six months before the start of
production, the electricity in the order of 0.5
billion. DKK corresponding to the investment
in oil stock for diesel generators. In addition,
a project loan of 4 -6 years based on
payments from the mining company - an
estimated 1 billion DKK.
The project loan can be based on a number
of lenders, for example, Nordic Investment
Bank, the European Investment Bank, export
credit linked to stock supplies, and of course
the Greenland banks. Alternatively, project
loan provided by the mining company.
It must be considered appropriate that the
hydropower plant is owned by the Self
Government, and run by a special project
73
company under the daily management of
Nukissiorfiit.
14.5 Billing Practice for electricity
With a significant economic framework
available there is a need for a billing practice
for the electricity.
It appears reasonable that the main added
value is for the Self Government with the
following profile:
• The price (for electricity) can be directly
related to the price of oil. This makes the
mining company neutral.
• There is no significant problem regarding
CO2 quota, which will be beneficial for all
parties.
The agreement could include compensations
for the mine company during the
construction phase.
• The price can be related to steel price to a
certain extent.
• There may be a compensation for the
possibility of supply disruption related to
Please confer response to question 5.1 and 5.2
-
None
74
failure of supply to aluminum melts.
• If the mine project is delayed because of
the delay in the establishment of the power
supply this can be offset in the electricity
price.
• There may be negotiated an overall
discount of electricity price.
14.6 Scenarios for electricity use after mine closure
Since it is assumed that the life of the mine is
significantly shorter than the hydropower
plant life there is a need to find uses for the
power after mine closure regardless of the
plant will be fully paid.
An ammonia production at the Isua port, in
Nuuk or in Manitsoq is an option but other
scenarios should also be prepared.
Please confer response to question 5.1 and 5.2
-
None
14.7 Consequences
The above considerations, as well as recitals in my previous responses, may initially, result in a feasibility study prepared in cooperation between BMP and London
Please confer response to question 5.1 and 5.2.
-
None
75
Mining. This study should explore the most advantageous economic performance of the overall project using hydro-based electricity for the project. It should also be pointed out that the use of hydropower for electricity by the mine project involves a much higher value of each kwh, viz. 1.60 DKK per kwh than using an aluminum smelter approximately 0.10 DKK per kwh.
76
15. Landslægeembedet
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
15.1
The Health Service has received the hearing
of VSB/SIA report for Isua iron mining
project and finds that the report raises a
number of questions.
It is the Health Service’s task to monitor the
health of the population. We do not find
that the report's description of the impact
on public health is sufficient in its current
form, in order to make it possible to provide
a comprehensive response. However, the
report gives rise to the following
observations:
According to the Guidelines for Social Impact Assessments for mining projects in Greenland the company has to describe health issues concerning if the project will change the current health status in the project area.
DCE/GN: No environmental aspect
None
15.2 Effects on public health and quality of life
In relation to the expected impacts on public
health, the report states the risk of an
increase in the incidence of sexually
transmitted diseases, unwanted pregnancies
and abortions, HIV and tuberculosis. Alcohol
and drug abuse is not considered to pose a
major problem, as there will be a ban on
Details on the content of the medical tests (pre-
employment medical check and annual medical
examination as stated in 6.5.3 Health Services) to be
agreed with the Health Authorities.
DCE/GN: No environmental aspect
None
77
drugs in the camp, which in practice may
prove difficult to enforce.
The actions which are likely to be effected to
prevent are: health screenings, information
campaigns in the camp as well as the
limitations of the distance from the camp to
Nuuk and the accessibility of the city except
for occasional nights in transit in Nuuk.
These measures are relevant and may be
sufficient to the extent that it actually
manages to avoid the camp personnel to
have access to Nuuk population on a larger
scale. If it is shown that the workers are still
going to be a long-term transit in Nuuk (due
to weather conditions, technical problems,
ice in the fjord, etc.) or staying on vacation /
holidays, there may be need for further
action. It is crucial that this development will
be closely monitored.
Our Health Service would like to see a
concrete description of the contents of the
medical examinations envisaged.
15.3 Carrier Modes of resistant bacteria
One factor not mentioned in the report, the
All employees will undergo a pre-employment
medical check and annual medical examination as
DCE/GN: No environmental aspect
None
78
incidence of new and resistant bacteria,
which represent a growing and very serious
problem in many parts of the world,
including in China. Bacteria that Greenland
has so far been largely spared.
For example, Chinese personnel could be
carriers of a number of new and in
Greenland unknown resistant bacterial
strains that besides creating serious
problems for the individual, could pose a risk
of infection to both the general public and to
other patients in the study and treatment in
health care. Such contagion can lead to
increased morbidity, mortality for vulnerable
/ sick people, and lead to high costs for
treatment, contact tracing, preventive
measures, increased human resources,
cancellation of patient care, etc.
For example, the need to close a ward
because of the spread of resistant bacterial
strains could paralyze the hospital and incur
significant costs, as witnessed by the
individual cases of MRSA (methicillin
resistant Staphylococcus aureus), which has
so far been found in Greenland. It is clear
that the risk increases with the number of
immigrants and the number of personal
contacts with the public and the health care
system. This will to some extent be
stated in 6.5.3 Health Services.
79
prevented by implementing vaccination and
screening for entry in Greenland. One must
be aware that every visit to the country of
origin in contact with family / friends, etc.
could be a renewed risk situation in relation
to carrier state of resistant bacteria.
Therefore, it may be necessary to consider
launching screening of foreign personnel in
contact with the health care system.
15.4 Measures and conclusion:
In order to achieve the desired effect in
relation to the protection of public health,
the proposed health studies contain both
study infectious disease and carrier states.
The screening of carrier states must be
organized by the disease patterns and
resistant bacteria found in the areas laborer
comes from.
It will be essential to ensure effective
monitoring and reporting of both infectious
disease carrying modes. The development
must necessarily be monitored throughout
the chain of risk factors from the
development of disease and resistance
patterns in the home country, the
development of disease and carrier states in
the camp and in the general population. This
The details of the content of the monitoring plan for
the public health aspects to be agreed with the
Health Authorities.
DCE/GN: No environmental aspect
None
81
16 TIMMIAQ
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA
16.1 First of all, Timmiaq note that this is a comprehensive consultation material which forms the basis for London Mining Greenland NS 'application for an exploitation license for an iron mine project in Nuuk. It is therefore important for Timmiaq to point out the importance of the precautionary principle enforced for this project. We do not want another “Maamorilik” where ignorance, we hate to use the term deliberately environmental pollution - has led to pollution of the bay, so the local population 20 years after mine closure still cannot collect clams and other animals in the area.
This is a matter for the Grenland authorities.
BMP: The environmental area related to mining is regulated in accordance with best internationsl standard. National Center of Environment and Energy (DCE), and Greenland Institute of natural Resources are independent consultants guaranteering this.
None
16.2
Timmiaq is concerned about London Mining’s plan to deposit excess ore and chemicals from the production of iron in lakes near the mine. Much of this residue discharged into lakes will be the toxic sulfur. Furthermore, it emerged during the public hearings that Australia has experience with the chemicals that London Mining plans to use for separating sulfur from the ore. In Australia it is advised not to discharge these chemicals in nature. With reference to the
Comprehensive geochemical testing have shown that the depositing of materials from the mine in a deep depression of a lake (glacial lake with naturally turbid waters, no fish habitat and low biodiversity) near the process plant will not lead to pollution of the fjord with chemicals, metals or other substances, including phosphorus. Continuous monitoring of the discharge from the lake will take place.
BMP: Discharge to the nature has to follow international best practice and the requirements in the government approvals has to be set after guidance of DCE and GN.
None
82
precautionary principle Naalakkersuisut is requested to prohibit this, since you cannot know what secondary damage effects this can have on an Arctic environment such as the Greenlandic.
16.3
Timmiaq has noticed that London Mining intends to transport ore in pipelines. Timmiaq is not convinced that the excess water from the transport in the short or long term does not pose an environmental risk to flora and fauna in Godthåbsfjord. We will, therefore, based on the precautionary principle recommend that the excess water is not discharged into the fjord, but recycled to furrow the ore forward. Timmiaq therefore propose that the pipeline be designed as a closed system where water is pumped back and re-used. Furthermore must the loading of the ships take place in a way that prevents dust to spread to avoid pollution.
It is not practical to have the pipeline transporting iron concentrate to be a closed system (the process plant and port area are separated by 105 km). The water from the slurry will be dewatered and before being discharged to the fjord the water will stay in a retention pond for 10 days for any suspended material to settle. When the water is subsequently discharged to the fjord it will meet the water quantity requirements and will not contain substances that are harmful for the environment.
BMP: The BMP are well aware of possible dust issues based on for example knowledge from mining in Nalunaq and Seqi. The regulation related to dust issues will be focusing on the issues raised in the question. DCE/GN: Nothing to add.
None
16.4
Timmiaq notice that the slurry subsequently
will be transported away in the large tank
ships. Because these tankers arrive without
cargo to Greenland, they will have to empty
the ballast tanks in Nuuk Fjord. This will
represent a great danger of alien invasive
species and to permit this would be
irresponsible. As a minimum, the
This is a matter for the Greenland authorities.
BMP: There are international rules
related to ballast tanks. Requirements
related to ballast tanks in the
government approvals will be based on
these international rules and can even
be more strict than these rules. It is
possible to follow the maritime related
conventions even if these are not yet
None
83
international environmental rules that apply
to Antarctica, should also apply in Greenland
and in the northern Arctic.
Knowing that international work on common
rules against contamination by emptying
ballast tanks currently takes place Timmiaq
still strongly recommend that, until there is
evidence that Ballast Directive is a safe
environmental regulations, it is required that
the ships do not carry water from other
ecosystems and empty their tanks in
Greenland waters or waters where the
current head towards Greenland waters. It
must be a minimum requirement that ships
from foreign continents arriving to
Greenlandic waters imposed under way to
replace the water in their ballast tanks every
other day, so that the local flora and fauna
are not affected by total strangers species.
Ships in ballast tanks include water not
originating from Arctic waters to be denied
admission in Greenlandic waters.
ratified. Requirements related to ballast
tanks including replacement of water
will therefore be regulated in the
government approvals.
DCE/GN: Reference is made to answer
7.1.
16.5
Also make sure that the fuel used in ships' engine on the many freight and ore transport is not the polluting heavy fuel. Burning of heavy oil is extremely toxic, and you do not know the environmental impact of this pollution in the Arctic. Since it is
This is a matter for the Government of Greenland and the general practice in the shipping industry.
BMP: The Greenland Government will not allow use of heavy fuel in inland waters. DCE/GN: Reference is made to answer 7.1 and 13.11.
None
84
technically possible to sail with easier and less polluting fuel the Self-Government as a precautionary principle, should require that all navigation in Arctic waters only use light fuel. Naalakkersuisut should in general work on that in cooperation with our neighboring countries and make it a general requirement that navigation in the Arctic only happens with the least polluting fuels.
16.6
Generally, Timmiaq is concerned by the increased transport in the fjord and the environmental risks arising from such a large port on the bottom of Godthåbsfjord, as envisaged. Timmiaq fear that the port facility could lead to incalculable consequences for the ecology of the inlet system. In particular, we are concerned about Nipissat Sound. The sound is currently designated as an IBA (Important Bird Area) and it is a candidate to be Greenland's next Ramsar site.
LM will ensure compliance with the strictest regulation in connection with shipping in the fjord to minimize the risk of accidents, including oil spill.
DCE/GN: Nothing to add.
None
16.7
The entire Nipissat Sound is a natural area
with large numbers of waders during
migration periods. It is probably Greenland’s
most important staging ground for waders.
The area also provides food for large
numbers of eider, king eider and other ducks
in the winter. The sound makes it the most
unique and important area for birds
throughout Godthåbsfjord.
This is a matter for the Greenland authorities. However it should be noted that staff at the mine is not allowed to leave the mine area during their working period , for example to visit the mentioned islands.
BMP: Rules related to shipping and possible related special status zones will be set in the government approvals. DCE/GN is aware of the importance of Nipissat Sound. The area will be at risk of exposure, if accidents happen in the mouth of Godthåbsfjord, but will not be affected by the daily operations.Consideration to the area will be handeled through the regulation and emergency preparedness of
None
85
Timmiaq has on several occasions observed
up to 700 individuals of ringed plover on the
shallow mud flats in the sound, like other
waders as turnstone, purple sandpiper,
dunlin; knot is seen in considerably numbers.
Rare North American species are also
observed annually. Guillemots, thousands of
eider, king eider and other ducks feed in the
sound.
Nipissat Sound with its shallow mudflats
especially sensitive to even small oil spills
and other pollutions. With increased traffic
of oil tankers and other cargo ships, the
potential for contamination of this unique
sound increases. An accident of greater or
lesser extent or careless discharge of ballast
tanks could result in substantial and
irreparable damage to the shallow areas and
the flora and fauna.
Similarly, it must be assumed that the
discharge of sewage and other pollution
from buildings in connection with the mine,
and the shipping and port activity will flow
into the strait and result in increased
pollution to the detriment of the entire
ecosystem of the Sound.
shipping.”
86
Such contamination will also impact the
black guillemots, eider, king eider, lump
sucker etc. are commercially exploited by
hunters in Nuuk, and thus have an impact
on an already pressured industry.
Timmiaq also notes the following of specific
relevance to the birds in the affected area:
In the immediate vicinity of the port area in Qugssuk are a number of smaller islands with a nice stock of a number of breeding gull species, possibly Arctic tern and eider. These islands must ensure a zone of sailing and prohibited during the breeding period.
16.8 It must be examined whether the "tailings" or other discharged materials could affect mussel beds in the northern part of Godthåbsfjord. These mussel beds have a significant importance as a food source for a large part of the Greenland wintering population of eiders from Greenland and Canada. Including whether there can be no accumulation of such. heavy metals in mussels and subsequent eider ducks and humans / predators.
The analyses that have been carried out show that pollutants from the mine will not be discharged into the fjord. To document that the environment is not being polluted a monitoring program will be implemented. The program will be designed in cooperation with the authorities. The monitoring will include mussels near the port area. The results will be compared with data from mussels collected three different years before mine start. See also response to question no. 4 in the minutes from the 3rd public hearing meetings .
DCE/GN: Reference to answer 7.1
None
16.9 In connection with the construction of various port facilities and other installations, ensure passport late the measures so that there is no disturbance, for example.
London Mining will ensure that disturbance of birds, and in particular bird colonies, is minimized during construction and operation of the mine (cf the EIA, section 6.2.2 LM will furthermore ensure that
DCE/GN: Nothing to add. None
87
helicopter traffic, navigation etc., of the significant bird cliffs that are in the inner part of Godthåbsfjord and particularly by Ilulialik's mouth.
existing regulation by the Greenlandic authorities, for example that helicopters must keep well clear of bird colonies, are followed.
16.10 There should be examination of how and where large populations of geese (Canada geese and white-fronted geese), which raster spring and / or fall on the low-lying Narssarsuaq area. Including whether there should be restrictions on traffic in the area north of the road at certain times of the year. A study of this issue may want. made by flyrekognoscering in May and September.
A draft monitoring plan is included in the EIA section 10. The plan will be further elaborated before mine starts operating in co-operation with the Greenland authorities. This will most likely also include surveys of staging geese. It should be noted that mine staff will not be allowed to leave the mine area at any time, except for the scheduled rotations to return home.
DCE/GN has prepared a document summarizing the proposed monitoring programs. The document includes monitoring of geese.
None
16.11
The level of impact on birds (geese, etc.) from blasts at the open pit should be examined so that any harmful effect can be eliminated.
The monitoring program mentioned under 16.10 will also monitor potential disturbance from blasting. London Mining is aware that during a short period in spring the mine area is potentially an important staging area for the endangered Greenland White-fronted goose.
DCE/GN: Nothing to add. None
16.12 Finally, Timmiaq encourage Naalakkersuisut to the interests of the environment imposed on London Mining, using hydropower rather than a CO2-polluting diesel power plant. There have during the civil hearings have expressed doubts about London Mining calculations of costs - costs and profitability through the use of hydroelectric power rather than diesel power. It is Timmiaqs believe that with regard to the precautionary principle must always be required to serve at least polluting technology used, ride possible.
Hydropower is not an option to ISUA project. Please see responses to question no 5.1; 5.2; 12.3 and 14. The financial analyses were carried out by SNC Lavalin, an internationally recognized large engineering firm.
DCE/GN: Nothing to add. None
88
16.13 Timmiaq must finally ask Naalakkersuisut to environmental and natural assessments of mining projects now and in the future are not treated in BMP and should be shifted to treatment in the Ministry of Nature and Environment, now Ministry of Domestic Affairs, Nature and Environment.
This is a matter for the Greenland government. BMP: This entered into force on January 1st 2013
Ingen None
89
17. Grønlands Arbejdsgiverforening
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA
17.1
Refered to the invitation on 16 August 2012
of the responses to the Social Impact
Assessment (SIA) and Environment Impact
Assessment (EIA) in the London Mining
Greenland's application for an exploitation
license for iron mining project at lsukasia,
Nuuk.
1: General Greenland’s Employers' Association (GA) main point is that the process of designing the upcoming Impact Benefit Agreement (IBA) is to ensure that the greatest possible value returns to Greenland. The purpose should be to provide an effective, socially and economically sustainable value added in the country. It must be in the form of a long-term capacity building in the local economy, so companies will be able to take on an increasing number of tasks within the mining sector in general.
No response is required.
-
None
90
The purpose will be achieved through maximum involvement of local businesses and their employees in the tasks to be solved in connection with both facilities and operating iron mine. It requires that in IBA'en formulation of clear and precise requirements for London Mining that the local is the first choice for jobs and sub-contracting, and that London Mining is imposed a proactive responsibility so the requirements and objectives, set in IBA'en, gets achieved.
GA would strongly encourage the industry
and other relevant stakeholders now get
involved in collaboration in the formulation
of these requirements to the IBA, and that
around this process establishes a clear
cooperation and decision-making structure.
Otherwise fears GA serious that economic
growth and supply of skills and local jobs-as
the great iron mining project is to cause,
doesn’t become a reality or only to a very
limited extent.
Greenland’s Employers' Association (GA) has
based on its consultation response to the SIA
comissioned this drafted report: 'Raw
materials and sustainable economic growth'
(Copenhagen Economics, October 11, 2012).
91
17.2
GA agrees with the report's conclusions and
recommendations, and will at least by
reference to the Canadian experience
highlight Best Practice-experiences learned:
1. Got a good started:
In the first place, among others, that "lmpact
benefit Agreements ... has to describe the
positive effects the project has on the area
besides the public revenue. More specifically
must the benefit plan include setting strict
goals for the extent of local workers among
others, apprenticeships, skill upgrading
courses, funding education, research and
development and the use of subcontractors.
The IBA should basically ensure that local
people have first priority. If a local jobseeker
meets a vacancy qualification, he has to be
hired at the expense of non-local job
seekers, who are also well qualified. "
GA recommends that now, in collaboration
with relevant stakeholders, take steps to
establish a benefit plan, which together
coordinate and prioritize social demand for
iron mining project in order to achieve
maximum impact in negotiations.
Comment is a matter for the Government of
Greenland .
BMP: The issues will be a part of the
Impact Benefit Agreement
negotiations.
None
92
17.3 Second follow-up: "Follow-up on such IBA-goals and ongoing dialogue with relevant stakeholders about various challenges that arise and coming new initiatives. It is quite complex in Canada, where stakeholders are among the Aboriginal groups, unions, employer associations, etc. at a very local level (often it is the Aboriginal groups that own the resources the mining company wants to use, see Land Claims Agreement), on the territorial government level and at the federal government level. "
GA recommends that now in cooperation
with relevant stakeholders established an
effective monitoring mechanism /
organization that can supervise the
fulfillment of the objectives and
requirements that come into the benefit
plan.
Comment is a matter for the Government of Greenland .
BMP: The issues will be a part of the Impact Benefit Agreement negotiations.
None
17.4 Third, a well-functioning system of enforcement: "this ensures that discrepancies between everything from economic to cultural and environmental agreements can quickly be solved efficiently. Within the oil extraction has in Canada been set up a regulator (C-NLOPB2) to monitor and enforce agreements, including the IBA and environmental and safety obligations. C-NLOPB acts as a link between the federal government and provincial government. In
Comment is a matter for the Government of Greenland .
BMP: The issues will be a part of the Impact Benefit Agreement negotiations.
None
93
the event of breaches of agreements or obligations, can the C-NLOPB respond using proceedings, stoppages or at worst even retreatment of agreement." GA recommends that in relation to the iron mining project established a Greenlandic enforcement system with the same overall purpose.
"Based on such a structure is the content of
the IBA key to a good start. Below shows the
Canadian experience that two factors largely
control how successful the community is in
negotiations with the mining company. Both
conditions agree on the objectives and the
ability to stand together and speak with one
voice. "
17.5 2. Proactive outsourcing The report also highlights that one thing is that the IBA specify the extent of outsourcing from mining company to the local economy. Another thing is, "... that the outsourcing sits in a permanent strengthening and upgrading of business requires a more proactive outsourcing strategy from mining companies. An example of such an approach from the Diavik mine. The company appealed a proactive approach to outsourcing, which ensured a high degree of outsourcing and helped local businesses to spot subcontracting opportunities ... "
Comment is a matter for the Government of Greenland .
BMP: The issues will be a part of the Impact Benefit Agreement negotiations.
None
94
GA recommends that the requirement for proactive outsourcing in elevant extent gets integrated in the IBA for iron mining project.
17.6 3. Strong bonds From the Canadian experience is highlighted in the report that "Mining companies operate in local communities for several decades. This long-term presence can be used to strengthen the bonds between the mining company and the community." "For this purpose can the tangible and measurable corporate and social responsibility (CSR) objectives be a good tool. Employer's Association for mining companies in Canada (Mining Association of Canada (MAC)) launched in 2004 six TSM principles reflecting mining companies' behavior in the field. .. " GA recommends that precisely the efforts to promote CSR in Greenland - including led by CSR Greenland - also naturally need to be extended to include the new industries that now are on their way to Greenland in the development of the mining sector. These requirements should also be formulated in the design of the IBA.
Comment is a matter for the Government of Greenland .
BMP: The issues will be a part of the Impact Benefit Agreement negotiations.
None
17.7 II: Specific comments on the SIA Greenland’s Employers' Association (GA) has gone through London Mining's recommendations for tasks to be offered. Here are used the terms 'local', 'mixture' or
Noted and these are issues in the IBA discussions.
-
None
95
'international'. The GA's opinion that the tasks that can be raised locally, has to be offered locally under the current Greenlandic rules for the provision of construction tasks (AP 95) or other known contractual basis, if it is not about construction works.
GA recommends that London Mining's
definition of "mixture" is changed, so that
tasks both can be offered to a joint venture
between
local and international companies, and that
also must be able to divide tasks so that
parts of the tasks are offered locally, and
that other parts are offered internationally.
17.8 To ensure that the Greenlandic companies and the Greenlandic workers get such a large proportion as they can lift, it is important that both the Greenland Employers' Association and SIK are closely involved in the negotiations on the IBA. See also the general recommendations in section I: 1 – 3
Comment is a matter for the Government of Greenland .
BMP: Noted. None
17.9 It is the GA's opinion that the Greenlandic companies can be involved in a significantly larger proportion of the tasks than what London Mining recommend. GA's recommendation for what is offered locally respectively mixed or international, is
This is a matter to be discussed and negotiated in the IBA.
- Will make some changes in the table.
96
shown in the table below. GA has made the assessment on the basis of the opportunities for competition in local offering.
Cf. Table Details Descriptions below
17.10 Ill: Concrete comments to the EIA
It is not clear from the EIA, who should pay
for the extra CO2 emissions. It should be
apparent from the EIA, who bears the cost
thereof.
GA is of course available for any questions
and clarifications on this consultation.
Comment is a matter for the Government of
Greenland .
BMP: Expenditures related to extra CO2 emissions will be paid by the polluter (company). In Denmark's ratification of the
Protocol, Greenland will be given a
territorial exemption, which means that
Greenland does not bind to the high
reduction commitments.
None
Details Descriptions:
Potentielle aftaler
London Minings
År GA·s
Indstilling
Boring lnternationalt 2012 Blanding
Logistik support Blanding Fra 2012 Blanding
Tilsyn på stedet Internationalt 2012 lnternationalt
Undersøgelse Internationalt 2012 Internationalt
Helikopterstøtte Lokalt Fra 2012 Lokalt
Pakke for civilt byggeri
lnternationalt 2012 Lokalt/blanding
Anlægsleire Blanding 2012 Lokalt
Havnens
lagerplads
Blanding 2012 Lokalt
Genereller service på
pladsen
Lokalt Fra 2012 Lokalt
Lufttransport Blanding Fra 2012 Blanding
97
Generel pakke
for fabrik
Internationalt 2013-2015 Internationalt
General pakke
for civilt byggeri
lnternationalt 2013-2015 Lokalt
Permanente lejre
Blanding 2013-2015 Lokalt
Pre-stripping af mine
Blanding 2013-2015 Lokalt/blanding
1 Se bl.a. Kapitel 4: Læringen fra Canada i 'Råstoffer og bæredygtig økonomisk vækst, Copenhagen Economics, 11.oktober 2012, Grønlands Arbejdsgiverforening'. 2 Canada-Newfoundland and Labrador Offshore Petroleum Board (CNI.OPB). 3 Råstofdirektoratet (2012), s.46 4 Råstofdirektoratet (2012), s.40
98
18. Kommuneqarfik Sermersooq
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA
18.0 Kommuneqarfik Sermersooq is grateful for the opportunity to contribute to this consultation and would like to take this opportunity to point out that it is the hope of the municipality that an exploitation license can be granted for London Mining’s iron mining project at Isukasia. It is the municipality's general assessment that there are no social or environmental issues in the material presented for public consultation that cannot be solved in a satisfactory way in connection with the construction and operation of the mine as described in the consultation documents.
Kommuneqarfik Sermersooq is therefore
positive to the new opportunities the
described project can bring to the society.
This include a rising income generation,
increased societal proceeds to the
development of welfare, building experience
in mining, development of new education,
job and career opportunities and the
creation of jobs and the resulting
opportunities for tasks to other Greenlandic
General introduction – no response is required - None
99
companies.
A project of this scale is not without risk and requires of course a serious assessment of both the social and the environmental impact. A project of this scale cannot avoid creating some friction and concerns about impacts on the environment, preparedness and risk of accidents, impacts on the local community and its ability to absorb them. Further is Kommuneqarfik Sermersooq aware of issues related to use of outside labor and its potential for labor organizing and acceptable wages and working conditions. On the latter issues reference is made to Kommuneqarfik Sermersooq comments regarding the consultation on "Act of Inatsisartut No. xx of xx. xxx 2012 on construction works at large scale projects ". Isua iron mining project can in a number of ways be considered from a national precedent perspective, and thus it is essential for Kommuneqarfik Sermersooq that the project will be carefully assessed, that it has been through an extensive information and consultation process. It should be essential for both the company and BMP that all stakeholders have an opportunity to be heard in the consultation process.
18.1 Social sustainability (SIA)
It is a clear aim in Kommuneqarfik
Sermersooq strategy on raw materials that
Statement by Kommuneqarfik Sermersooq.
BMP: Many of the issues mentioned will be addressed in the IBA process.
None
100
local workers and companies are to ensure
the best possible conditions for active
participation and development of skills in
relation to a mining / large scale project.
Therefore, Kommuneqarfik Sermersooq,
both has this focus in this consultation and in
the coming Impact Benefit Agreement (IBA).
Kommuneqarfik Sermersooq notes that the
revenue from taxes duties from such a
business project is of course important, but
equally wants Kommuneqarfik Sermersooq
the project will contributor in the secondary
effects such as capacity building and
development of local workers and
enterprises with use of international
experience. This is achieved through close
dialogue with education institutions,
vocational educations and similar
institutions (see descriptions in Annex 3 to
the EIA).
"The Mining Act provides the opportunity for
that the Greenlandic economy is given
priority to tasks related to the exploration
and exploitation of mineral resources, if
companies are competitive in terms of prices
and quality. Kommuneqarfik Sermersooq
wants to support the development of skills
at company level in order to meet the
demands of t BMP and industry, by creating
101
a framework conditions for the development
of local businesses. "
Kommuneqarfik Sermersooq want to
emphasize the importance of the developing
the relevant sectors in the existing
Greenlandic business in parallel with a
project like this. Through dialogue with
industry stakeholders Kommuneqarfik
Sermersooq suggests that there will be
establishes a clear and concrete strategy for
how Greenlandic companies are been
prepared and engaged in the iron mining
project.
There are several relevant bodies (both
national and regional) through which London
Mining has the opportunity to seek
cooperation, in order to identify and
implement business development initiatives.
In collaboration with eg. Sermersooq
Business Council, Sulisitsisut and Rambøll
Greenland A / S. The sooner this dialogue
and, not least, the next steps are fleshed out
and realized, the quicker the Greenlandic
companies have the opportunity to enhance
their competitiveness and chances to win
assignments.
102
"It is crucial to address the areas of
knowledge and skills in the local economy.
This could be carried out by encouraging the
conclusion of strategic alliances, consortia,
development of quality control and
certification systems, etc. "
A particularly important consideration is to
ensure great attention to which if the
assignment that will be offered to local
companies. This can imply for a need for
special flexibility in relation to spilt-up of
large contracts so they become more
available for local companies.
Kommuneqarfik Sermersooq is aware that it
may be desirable for London Mining to
engage with few companies to larger
contracts, in these cases, large foreign
contractors also weighed on their ability to
enter into strategic alliances with local
companies. Kommuneqarfik Sermersooq is
convinced that there will be a number of
benefits for London Mining by giving priority
to cooperation with local companies,
including local knowledge such as local
weather conditions, valuable experience
with the local ground and underground, and
a deep knowledge of the legislation and
environment and relations to the business in
Greenland, etc.
103
"The development of mineral resource
requires a coherent strategy in the areas of
business development, labor marked,
facilities and environment. Kommuneqarfik
Sermersooq assesses on-going the need for
alignment of management and cooperation
between the various agencies. "
18.2 Within the areas where municipality is the authority, Kommuneqarfik Sermersooq will ensure a smooth handling of project start-up, construction and subsequent operation. For this to be realized, it is necessary that the Kommuneqarfik Sermersooq is organized dedicated to this task. At the same time, it is necessary for Kommuneqarfik Sermersooq to receive more information on how London Mining will organize themselves, as well as additional information about in what ways and to what extent London Mining expects to draw on municipal services.
London Mining will provide additional detailed information to Kommuneqarfik Sermersooq on the organisation and which services are expected from the municipality during the whole process
- None
18.3 Waste management. This applies to in waste management, especially in a phase before London Mining will set up their own waste disposal facilities. In this specific regard, Kommuneqarfik Sermersooq wish a deeper knowledge of London Mining expectations of quantities and types of waste to be handled by the municipality. When there is a request to draw on Kommuneqarfik Sermersooq services for handling and disposal of waste, it is the starting point for the municipality
Comment noted for future detailed planning of
waste disposal during construction phase. If it should
become applicable, London Mining will take the
initiative to discuss this further with Kommuneqarfik
Sermersooq in order to make the planning in
accordance with the plans of the municipality.
BMP: Requirements related to waste management will be set in the government approvals. It is the full responsibility of London Mining to remove waste and pay for the costs related to this. DCE/GN: Nothing to add.
None
104
that this must be based on agreements between the municipality and the company on commercial terms. It is essential for Kommuneqarfik Sermersooq to highlight that in a exploitation license it should be clear that the municipality has no obligations regarding waste disposal from the company and the municipality's possible involvement in waste disposal for business can be done on commercial terms. Re. waste management for the company reference to the SIA Report page 96-97 and page 163, and the EIA Report on pages 26-27, pages 79-81, pages 149-150 and pages 175-176.
See also answer no. 11 from the 3rd Public Hearing
meeting (24. September 2012).
18.4 Jobs and needs for housing in Nuuk. Additional, Kommuneqarfik Sermersooq would like to gain deeper insight into whether London Mining, now and in the future, expect an expansion of facilities and number of employees physically located in Nuuk, for example with regard to the establishment of headquarters and administrative functions. If London Mining expects a higher growth in this connection, it would be appropriate for all parties that Kommuneqarfik Sermersooq are advised in due time. This may, for example relate to land allotment and approval of construction projects, construction of staff housing, childcare places and schooling for the
The amount of persons (50 – 100) is stated for the
mine life (operation).
However, this will not be the case during the
construction.
If it will be the case, London Mining will take the
initiative to discuss this further with Kommuneqarfik
Sermersooq in order to make the planning in
-
None
105
children of employees and other issues of local government units. Regarding expansion of its activities in Nuuk see SIA page 138, which include between 50-100 people with long-term living in Nuuk.
accordance with the plans of the municipality.
18.5 In addition, Kommuneqarfik Sermersooq wish as a general principle, the establishment of cooperation with the relevant parts of the municipality administrations, in order for the administrations to be able to participate in the project's construction and operation as appropriate as possible, from the reasons administrations have to carry out. In this respect, Kommuneqarfik Sermersooq would like to discuss proposals from the company on action plans for cooperation with local labor and business administration as well as with Sermersooq Business Council. This will be of benefit from all sides in the engagement of local enterprises and labor, as well as the necessary education, training and development of skills.
London Mining will cooperate with the different departments of the municipality during the planning, for both construction and operation phases.
- None
18.6 Airstrip It appears from the material that London Mining will not initially plan to build an airstrip in the license area, for aircraft of the type Dash 8 or similar. Thus, the air transportation of passengers and freight had to go through Nuuk Airport. Kommuneqarfik Sermersooq does this prove that the
Comment noted for future detailed planning and
discussions between the relevant parties.
None
106
transportation needs for London Mining through Nuuk Airport push for an extension of the airport and extension of the airstrip, therefore, Kommuneqarfik Sermersooq proposes to initiate concrete discussions on the extension of Nuuk Airport between the relevant parties, including London Mining.
18.7 In general, the above factors are considered as examples of considerations that will be relevant if an exploitation license will be granted and the construction of the project have to start: Kommuneqarfik Sermersooq need a clear understanding of how London Mining intends to organize themselves in order for Kommuneqarfik Sermersooq can make the necessary preparations. Kommuneqarfik Sermersooq is looking forward to a direct dialogue with London Mining and BMP on these points, see also the recommended collaboration between the company and the municipality on page 164 of the SIA. "Workers of the Municipality of Sermersooq must be qualified and com-petent in relation to mining industry. Basic skills such as language and safety education, common core courses and similar should be encouraged. " Construction and operation of the iron mine will require significant inflow of skilled and unskilled workers from various sectors of construction, including construction, mechanical installations, erection of steel
London Mining will cooperate with the municipality. - None
107
structures, electrical installations, concrete work, automation and control, etc. This will be both a challenge and - in case of success - a strengthening of the Greenlandic labor marked. During the period up to and under the start of the project a significant upgrading of the Greenlandic labor will have to take place, so that a number of the employees could come from the Greenlandic workforce. This may also lead to such an extent that the well-functioning employees from their current assignments will apply for the iron mine, and thereby result in the existing positions in for example Nuuk be open for new employees. This may provide an opportunity to people who were previously unemployed, can undergo training and skills development to be included as permanent employees of the Greenlandic local environments. It should be a common goal of the establishment of the of the mine, that previously unemployed are upgraded and included in permanent employment as a result of the mine establishment.
18.8 At the same time, discussions should take place between the Company, BMP and municipality on how to measures and mitigate the adverse effects on the local labor market in Nuuk. This is to avoid a shortage of skilled labor in Nuuk in certain sectors and to avoid local overheating in the economy.
London Mining will participate in these discussions. - None
108
18.9 Specific comments on SIA. On page 69-70: Kommuneqarfik Sermersooq has implemented organizational changes and the report's description of the organization and the organization is no longer valid. New and updated material can be transmitted by contact with the mayor’s secretariat.
Actions will be taken.
-
The
organisation
of
Kommune-
qarfik
Sermersooq
will be
updated on p
69-70 (DK
version)
18.10 On page 135: The submitted contract packages are considered unambitious for the Greenlandic industry in order to maximize their participation in the project. This may be the case in categories such as "Construction Camps", "Ports storage area", "General package for civil construction", "Permanent camps" and "Pre-stripping of mine." This issue is expected to be subject to further processing in determining the terms in the license and in a IBA negotiation process.
Comments noted and will be dealt with in the IBA negotiations.
- None
18.11 On page 142-143: Section 6.1.4.2. describes a number of possible positive effects of tourism in Nuuk area, based on an increased local demand of tourism activities as a result of the establishment of the mine. The company should be ask specifically to obtain Sermersooq Business Council's assessment of whether there also may be negative effects on tourism of the mine construction, for example with regard to cruise tourism to Nuuk. If it is the case, that there may be
London Mining is in contact with the business council. It is not expected the ISUA will have negative impacts on tourism. In fact, it will help the developmetn of such industry. The majority of workers will be living and working in their camps.
- None
109
potential negative effects on tourism, apart from competition for accommodation capacity, this should be identified and there should be suggested possible mitigating measures.
18.12 On page 162: In the material is mentioned as an example the logistics of person via Nuuk. Kommuneqarfik Sermersooq would like to hear more about the plans for those cases where a large amount of employees potentially could "strand" in Nuuk due to weather or other delays. Especially the plan of management this situtaion, and whether it is expected that Kommuneqarfik Sermersooq will have a role in these situation.
London Mining will share detailed plans on the logistics of personnel with the municipality.
- None
18.13 On page 168 and 169: Kommuneqarfik Sermersooq is aware of the listed risks of social conflicts during the construction phase and operation phase respectively. It should be expected of London Mining, that London Mining continuously monitors the social interaction between the community and the employees on the project and take the necessary precautions if adverse situations should arise, see also on page 171-173 for the proposed mitigations measures. Kommuneqarfik Sermersooq hopes that the inter-relationships between project staff and the local community will be further discussion with the municipality, both to minimize risks and, if possible, to create opportunities for positive social interaction between the community and the staff of the project.
London Mining will discuss this further the municipality.
- None
110
18.14 For logistics of goods, stated at for example at page 163, the Kommuneqarfik Sermersooq notes that the municipality wants notification in due time, if there is a need for building and industrial areas in Nuuk - this can play a significant role in the municipality's existing land and planning strategy.
London Mining will advise the Municipality. - None
18.15 Kommuneqarfik Sermersooq welcomes the draft monitoring plan, as found on page 210-211. A thorough and continuous monitoring will be an essential tool in cooperation with the municipality and other stakeholders.
No response is required. - None
18.16 Environmental impacts. "Kommuneqarfik Sermersooq want the exploitation of raw materials from the Greenlandic nature is on a sustainable basis, and with utmost respect for the sensitive Arctic environment and the local population. The people of Greenland have traditionally lived by nature. Fishing and hunting are still a big part of the culture and an essential part of the Greenlandic diet. There are important breeding and resting places for birds, fish and animals, which must be taken utmost account of projects in the open country. " Overall, Kommuneqarfik Sermersooq expects that the strictest possible measures to protect the environment will be taken. Both with regard to the choice of technical solutions and in the choice of materials and in the ongoing monitoring and reporting
The statement by Kommuneqarfik Sermersooq is
noted
-
None
18.17 Contingency Kommuneqarfik Sermersooq lacks detailed
111
information on contingency plans related to the environmental risks of the project, including shipping to and from Nuuk port and the port facility at Taseraarsuk. The expected involvement of Kommuneqarfik Sermersooq in area of contingency plans and in license is not finally described. Kommuneqarfik expect that the "emergency" is elaborated separately in terms of the license.
It should be stipulated that the company is
financially and operationally responsible for
both anti-pollution preparedness in all areas,
including mining area, pipeline, port facilities
and transport within the limits of the
municipality. The extent of Kommuneqarfik
Sermersooq’s operational preparedness is
extremely limited and the municipality will
not have opportunities to be engaged in
these type of task. Emergency planning and
pollution control discussed in EIA include in
Section 7.4 (page 241-248) and in Annex
sixth.
Comment noted for future detailed planning and
work on contingency planning.
See also answer no. 3 from the 3rd Public Hearing
meeting (24. September 2012).
BMP: Contingency and emergency
related issues will be regulated in the
government approvals.
None
18.18 Shipping. Regarding shipping Kommuneqarfik Sermersooq expects that the conditions of the exploitation permit will include the conditions for shipping in connection with the project. Including conditions on the use of fuel, taking into account the potential damage to the environment in pollution
Comment noted for future detailed planning and
negotiations with BMP and DMA.
See also answer no. 1, 2, 3 from the 3rd Public
DCE/GN: Ships associated with the Isua
project must, like vessels participating
in oil exploration in Greenland waters,
None
112
cases, conditions on ships' design and construction suitable for sailing in icy waters, conditions on emergency board to combat oil pollution conditions on the use of pilot for navigation in the baseline and conditions on the management of ballast water so that there is no risk of contamination of the marine environment with foreign substances and organisms from ships' ballast water. It should be noted that both approaching the coast of Nuup Kangerlua and by sailing into the fiord is a significant risk to both grounding, collision with ice or other vessels.
Hearing meeting (24. September 2012) not use heavy fuel. (see 13.11).
18.19 Furthermore, and in line with the document "DCE / GNIR comments on EIA for Isua project, Section 9", in the EIA there seems to be insufficient evidence of effects on marine mammals, fish and birds of underwater noise from the increased and heavy ship traffic in Nuup Kangerlua with large ships. Kommuneqarfik Sermersooq endorses DCE / Pinngortitaleriffiks comments and to request that the company be required to follow DCE / Pinngortitaleriffiks recommendations. "Kommuneqarfik Sermersooq want the authorities to set high standards for limiting emissions and accumulation of harmful substances in the exploration and exploitation of raw materials."
Comment noted.
See answer no. 38 from the 3rd Public Hearing
meeting (24. September 2012)
See answer no. 4 from the 3rd Public Hearing
meeting (24. September 2012)
DCE/GN: Nothing to add.
None
18.20 Pollution Risks. Annually, there will be discharged about 7.4 million m3 process water (waste water) from dewatering of suspended iron concentrate for Taseraarsuk bay containing residues of
The statement by Kommuneqarfik Sermersooq is
noted.
BMP: There will be requirements in the government approvals. There will be exact temperature limits related to the
None
113
process chemicals, nutrients nitrogen and phosphorus, and in addition, the discharged water is significantly warmer than the surrounding water temperature. This locally significant wastewater discharge and potential environmental impact should be monitored carefully, as well as there should be set acceptable levels for hazardous substances in wastewater discharge. In the material, it is clear that there will be discharged with the process chemicals to both the fresh water reservoir and the marine environments. Since there is a possibility of a potentially harmful effect on the environment from the process used chemicals, it is desirable that the discharge of these minimized. It should be examined with reference to best available techniques on the desired used chemicals can either be avoided, replaced by less hazardous chemicals or completely removed during cleaning in the process. In any case, Kommuneqarfik Sermersooq requests introduction of limits and monitoring programs for discharges of hazardous substances and require adequate techniques for the mitigation of environmental impacts.
See also answer no. 4 from the 3rd Public Hearing
meeting (24. September 2012)
discharged water. DCE/GN: Reference to 7.1.
BMP: There will be requirements in the government approvals.
None
18.21 Significant amounts of dust and particles are expected to be released into the environment in relation to the project. Best available technology to reduce emissions should be used in the project. Kommuneqarfik Sermersooq expects that one will be very aware of this. Additionally,
The statement by Kommuneqarfik Sermersooq is
noted.
BMP: There will be requirements in the government approvals. DCE/GN: Reference to answer 7.1.
None
114
Kommuneqarfik Sermersooq recommend emissions of soot particles to minimized.
18.22 Caribou.
Regarding the influence of the population of
caribou in the area, BMP are requested to
ensure that the negative effects of the
population will be avoided as much as
possible. Particularly BMP is requested to
consider specific rules for the activities in
the area during the period in May and June
when the rolls calve.
The statement by Kommuneqarfik Sermersooq is
noted.
BMP: There will be requirements in the government approvals. DCE/GN recommend that use of the sites up to the concession area by the caribou population is monitored. On this basis, the needs for specific rules for road traffic in the caribou calving period will be prepared
None
18.23 During use of raw materials this has to be sought with the use of the purest possible and most energy-saving technology to limit emissions of greenhouse gases. In assessing the different mining projects in the municipality, the Kommuneqarfik Sermersooq will maintain principles of the Mineral Resources Act to use environmentally friendly technology and a high level of protection of the environment, nature and human health ". Unfortunately, Kommuneqarfik Sermersooq has noted that the company analysis does not support the possibility of developing hydropower as part of the overall project. Please refer to the financial and temporal perspectives, at the same time while the available water resources will not only be able to support 100% of the energy needs.
The statement by Kommuneqarfik Sermersooq is noted.
BMP: The Greenland Government is supporting the companies in finding the best hydropower solution for all the relevant mineral projects. It is also a requirement in the guidelines that hydropower has to be considered as part of the project. The hydropower potential has to be considered with respect to the already excisting hydropower scenario in the area. A scenario with hydropower at a later stage in the process is also considered. DCE/GN: Nothing to add.
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Kommuneqarfik Sermersooq must ask the
Selfgovernment to consider the possibility
of establishing hydropower supply for this
and possible other industrial projects, and
demand the use of environmentally friendly
technology and energy such as use of
hydropower, to the extent that it can be
implemented economically and practically.
From the point of view of the
municipalityshould one on not prevent the
possibility of hydropower supply to the Isua
project, even if a relevant hydropower
alternative may be established at a later
stage and a different owner and operator.
Kommuneqarfik Sermersooq notes that the
expected emission of greenhouse gases from
diesel-based power plants in the Isua
project, in large numbers is equal to the
total national emissions of greenhouse gases
in Greenland today. This is a dramatic
increase in our emissions of greenhouse
gases and at the same time a relatively small
contribution to the emission of greenhouse
gases worldwide.
The statement by Kommuneqarfik Sermersooq is
noted
18.24 Other comments "Kommuneqarfik Sermersooq want to be an
The comments and statements by Kommuneqarfik
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116
active party in collaboration with businesses and the Self Government of Greenland in the formulation of agreements on the implementation of the various mining projects, known as IBA, Impact Benefit Agreement, which establishes a framework for the parties' efforts such as education, use of Greenlandic companies and labor." If the project is realized Kommuneqarfik Sermersooq would like to see the opportunity to develop a positive and engaging collaboration with London Mining and further with the many visiting workers. Kommuneqarfik Sermersooq want to help develop a good working relationship between the municipality, the local population and the company, including the creation of a good interaction between the residents of the community and the project's external employees.
Additionally, Kommuneqarfik Sermersooq
would like to participate in solving other
tasks of environmental or social nature,
which can contribute to that the project will
develop in a good balance with its
surroundings, to the extent that it falls
within the municipality's capacity,
responsibility and competence.
Sermersooq are noted
117
19. SIK
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA
19.1
Consultation responses in relation to
consultation on London Mining's application
for an exploitation license for iron mining
project lsukasia in Godthåbsfjord at Nuuk.
SIK has the following comments, which we in
subsequent, chronologically will follow the
topics that are set for the following:
When in the presentation begins with Social Impact Assessment (SIA) will SIK already here to point out that we do not understand why all of Greenland have not been involved in the consultation process, as there is a national project that will come to impact throughout society. There is an insufficient basis for assessment by focusing only on a consultative process in Nuuk. The precondition for setting up and allow large-scale projects in Greenland, not least anchored in our entire society. SIK think London Mining Greenland here have neglected to involve citizens outside Nuuk.
The involvement of stakeholders in the SIA Processe
was carried out in accordance with the BMP
Guidelines and agreed with BMP.
After London Mining obtains the license to operate,
London Mining is planning additional public
meetings focusing on recruitment of local
employees.
BMP: It is always an assessment how
the hearing process related to the
different mine projects should be
approached. In the LM case all relevant
hearing materials have been published
on the national Nanoq.gl hearing portal
available for all residents in Greenland.
The public review meetings was
focused in Nuuk, as the project is
located in the Nuuk area.
The SIK comments are noted as basis
for an evaluation of the process.
None
19.2 SIK will also indicate here that the given consultation period has been too short in
Comment is a matter for the Government of Greenland
BMP: Comment related to the given consultation period is noted and will be
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118
view of the complex elements of the project consultation material that later is to form a durable solution and thus provide the basis for a final decision basis. The current report material (SIA and EIA) submitted by London Mining represents total 613 pages. In addition documents that makes up 1046 pages. The material, which latest was revised in July this year, must be submitted as a final consultation per today. The deadline for this consultation has been 8 weeks. In retrospect, it is SIK’s opinion that there has been a case of a too short hearing deadline sow the extensive material.
considered in the evaluation process.
19.3 EXTERNAL LABOUR? THE CONSTRUCTION PHASE? SIK particularly notes the whole handling of the issue of hiring outside labor. London Mining writes in its report, that there is to be recruited from 1500 to 3000 skilled workers from outside the construction phase. SIK therefore questions what the difference between the definition of a skilled and non-skilled is? By the review of BMP's own description of working conditions and job opportunities in the mining sector, SIK note that more than the half of the workforce in construction work does not necessarily classified as skilled workers, but rather as manual workers who are trained on the site concerned.
The ISUA project is a large construction project with
short completion period. All workers must be skilled
and able to perform from day one of their duties, for
all positions. It is not expected to have large amount
of on site training in construction techniques as it
will jeopardize the project in costs and schedule.
However, all construction workers will undergo
Health and safety training, environmental
protection training, and cultural sessions. Other
specific requirement will be determined in the IBA.
-
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119
In the present material, it however not appears how many residents who would be identified to employ. Based on this information, the SIK must conclude that we cannot currently expect the employment of local labor during the construction phase. In relation to the current high unemployment here in Greenland, the SIK fail to see what steps have been taken to combat unemployment related to this project. On this background asks SIK therefore: How much of the outside workforce can rightly be filled by unskilled Greenlandic workers?
The estimated percentage of labour hours by the
locals are estimated and presented in the SIA report.
The workforce during the construction as well as the
operation phases will only be skilled workforce.
19.4 Will Naalakkersuisut launch unemployment-fighting initiatives by hiring local workers during the construction phase?
And what has Naalakkersuisut initiated to
encourage the upgrading of the available
workforce in the meantime?
Comment is a matter for the Government of Greenland .
BMP: It is a focus area for the Greenland Government to have local workers involved in the construction phase. This will also be one of the main topics at the IBA negoatiation meetings.
The Greenland Government has already
initiated a number of activities in order
to upgrade the available workforce to
the upcoming tasks. Among others the
initiative run by RAMBØL GRØNLAND
by upgrading local companies to take
part in the construction and production
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Therefor the question of what conditions
Naalakkersuisut will attach to the project
around the aforementioned conditions?
phases has been launced. In addition to
this the PKU funds (Development of
Personal Competences) administered
by the Department of Industry and
Labour Marked have already to a
certain extend funded initiatives
directed at supporting the mineral
resources sector.
Issues related to education,
involvement of local business` and
involvement of local workforce will be a
part of the IBA negoatiations.
It is a requirement that the public
involvement is as big as possible but
the requirements also have to be
realistic.
19.5 The company also states that the effects of the direct local jobs during the construction phase are dependent on whether the local labor is available. SIK asks here, what is meant by this cryptic text which we frankly do not understand? And what explains the fact that London Mining write about what is locally available while attention is drawn to that the impact can be felt at the national level for a period of 3 years?
It meant the availability of the skilled local work
forces.
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121
19.6 OPERATIONAL PHASE? With regard to the operational phase SIK will indicate that it is of utmost importance that we get a complete and realistic picture of how many residents, who will be recruited? In the first 5 years of operation London Mining expects, employment of 20% of the local. What is the reason for this assumption? London Mining indicates that even in the first 5 years allegedly can hire up to136 residents. Complies with those 136 souls up to Naalakkersuisut’s ambitions and expectations? Also during the operational phase, we are introduced to concepts such as Chinese operators and Chinese supervisors. Is the use of Chinese technology as a pretext to use Chinese labor?
At the start of the operation, it is expected that no
local labour will be able to handle the technical
positions for most of the plants and equipment. It
was assumed that the Greenlandic workforces will
be mainly working in the port operation, logistic and
service areas. The local people must be trained
gradually to take other technical positions.
Therefore, foreign experienced and qualified
operators s will be needed at the beginning.
BMP: Immediately this does not seem as a high number, but this is one of the things that will be dealt with in the IBA negotiations.
None
19.7 SOCIAL DUMPING? One of SIK’s central core issues is in relation to the establishment of large-scale projects (thus London Mining) in this country are understandably how compensation should take place? SIK has throughout the progress so far insisted that the salary of outside labor naturally must follow the agreements agreed by the parties on the Greenlandic labor marked. This question has already given occasion to much discussion both at home and outside Greenland’s borders.
Moreover outstanding question concerning
the right to vacation, overtime payment,
The minimum wage of foreign construction workers
are defined in the large scale project Act. London
Mining will follow the law. The international
contractors will bid the project with their
expectations on the salaries, however, will be
required to fulfill the minimum wage requirement
by the government. It is impossible to request
everyone to bid with the same salary scale as it will
defeat the purpose of international bidding.
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122
coverage of disease etc.
It is of course an indispensable requirement
from SIK that the country’s agreements are
carefully monitored as precedent on the
other Greenlandic labor would otherwise
develop into 'Klondike’-like conditions in this
country, which in no way can serve to ensure
that the desire to maintain a welfare state
for all remains.
19.8 TAXES & FEES? Based on this present presentation from London Mining it shows that when speaking of corporation tax and charges we are talking about 28 billion DKK over 15 years (under 2 billion DKK annually). In addition, income of employees of 3.8 billion DKK over a 15 year period (250 million annually). SIK would like hear if the total amount given to end up in the Treasury, corresponds to the expectations Naalakkersuisut have imagined? SIK understand of the presentation on corporation tax that Naalakkersuisut intends to provide lsukasia project a special scheme, since the taxable income is determined because of the earnings, as stated in the statutory annual report? London Mining also states - while they refer
Comment is a matter for the Government of
Greenland
BMP: The expected revenue from taxation of the project depends on a number of variable factors. Naalakkersuisut in cooperation with external consultants is currently updating the economic expectations, including the revenue from taxation. There is no special arrangement
regarding the company’s taxable
income. This can be seen from London
Mining ISUA VSB page 11:” the
corporation tax for the Isua project will
be calculated by Naalakkersuisut”.
Naalakkersuisut has not imposed the
company royalties or resource tax.
Naalakkersuisut base its direct revenue
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123
to the Law on Mineral Resources that royalties or other extraction fees will not be available for lsua project. Tax on profits generated by extraction will be taken in the use of Naalakkersuisut. Should this interpretation be understood as that there still, in the technical sense, will be charged royalties? And if so, has Naalakkersuisut then taken into account to make room for a resource tax?
on corporation tax and profit tax which
will give Greenland a share of the profit
and which to a higher extent than
royalties will increase the revenue if the
price of the product increases.
Royalties are typically a tax on the
turnover in which the company has to
pay even if the production makes a
profit. By imposing royalties the risk of
the investment increases and thereby
the incentive to invest in new projects
which could generate more income to
Greenland.
19.9 APPRENTICES? The paper shows that the Company proposes to between 30 and 50 apprenticeship positions at the start of the operational phase. SIK will here call Naalakkersuisut to stipulate that London Mining as a minimum undertake to quantify on how many young people they will train. An agreement may be specified in an IBA agreement. SIK encourages by extension also to the London Mining meet demands for job training and qualification of all potential candidates for employment in the mine.
Noted and will be defined and covered in the IBA.
-
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124
20. Departementet for Sundhed
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA
20.1 Subject: Hearing of assessment of environmental impacts (EIA) for lsua iron mining project Department of Health thank you for hearing of the EIA for Isua iron mineprojeket. General Isua project is probably the first large-scale mining project in Greenland. It provides natural high demands on both completeness and level of detail in the EIA report for the project. This applies not least because this WM statement will probably fa knock-on effect on future WM statements. Follow-up responses This requires a great demands also to follow-up from the hearing responses. There are currently plans that the responses will be collected in a White Paper, but it is not entirely clear from EIA, what happens next. As an example, of the overall project which is not outlined in Figure 3.1. does not provide the answer.
Proposal: incorporation of hearing
responses are visible through the process,
by
Comment is a matter for the Government of
Greenland
BMP: Comment is noted
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125
inserting one phase after EIA called
"incorporation of hearing responses and
additional studies" and that this phase
generally clarified the requirement for the
EIA.
20.2 Analyzes of the combined effects The report describes to a great extent the separate impacts, but do not discuss the combined impacts. For the impact on the marine environment, the combined effects are important. An example here is that both discharged freshwater in the inlet system, which is warmer than the fjord water, and that this water may contain substances that are harmful to the environmental, while the combined impact of these effects on how the substances that are harmful to the environment are spread further in fjord system is not illuminated Proposal: That likely combined impacts are documented, discussed in the report / white paper and if necessary mitigated.
LM and its environmental consultant agree that in addition to an assessment of significant individual project components, an overall assessment must also be presented. The total effects of the Isua projects are presented in the “Conclusions of the EIA” page 38-41. The water effluent system at the Port area is designed such that to respect a maximum temperature during summer time of 10 C in the effluent discharged to the fjord, as per Canadian recommended limit for the temperature of effluent. In addition, at all other times in the fall and winter months, the temperature of the effluent at the port area was simulated to be lower than 10C. The comment in this question 20.2 has already been accounted for as part of a recommendation by DCE. Following its review of the EIA, DCE recommended to change the location of the discharge point at the Port area. In order to further maximize the mixing of the low temperature effluent, DCE recommended to locate the discharge point at a deeper water depth
DCE/GN agree that the temperature is only expected to be increased in a limited area. It is recommended to monitor the extent of the problem and on that basis decide on the need for regulations.
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126
area exposed to tidal and wind mixing. This recommendation by DCE was followed and the discharge point at the port area was relocated accordingly. This has been presented in the revised EIA which was issued for the purpose of Public Hearings. In addition, the delimitation at 10 °C of discharge water temperature for discharge of the effluent is adopted from the Water management policies, guidelines and provincial water quality objectives of the Ministry of Environment and Energy, Ontario, Canada, and is based on numerous water chemistry parameters. The subject is also elaborated in the EIA Annex 7, sections 4.5.2 and 5.4.
20.3
Analyses of cumulative effects
It is also characteristic that the report
analyzes and describes the immediate
effects, while a lesser extent describes the
cumulative effects over the mine life. For the
assessment of environmental impacts is of
great importance whether the substances
accumulate. This applies around the
environmental importance of emissions of
hazardous substances used in the process or
discharge of metals to the fjord system.
Proposal: That the cumulative effects
described and discussed in the white paper
and possibly the need for corrective actions
In normal EIA usage, and in the Danish EIA guidelines
issued by the Danish Ministry of Environment
cumulative effects are defined as impacts from other
existing projects or plants and/or approved projects
and plans. (cf. Vejl nr. 9339 “Vejledning om VVM I
planloven”).
LM and its environmental consultant are aware of
BMP’s requirement to take into account the
cumulative effects of other projects in the same
area. However, the Isua iron ore project is the only
scheme that has reached a stage where the
construction works have been defined and an
application to start construction has been submitted
DCE/GN: Nothing to add.
None
127
are identified. to the Greenlandic authorities for approval. It is
therefore not possible to assess specific potential
cumulative effects of other projects, such as the
Alcoa, since no detailed plans are available or
approved.
The effects mentioned in the question are
understood to refer to effects of the mine,
accumulating over lifespan of the mine. These are
shown in the modeling of concentrations of various
projected parameters. The concentration of metals
and residual reagents in the tailings pond is for
example presented in the EIA, section 7.1.12 and in
Annex 7, section 5.3. For metals it should be
compared to the high ambient levels found to be
present during baseline investigations, and the high
flow volumes of glacial melt water. For the residual
reagents, the EIA has presented the results of the
geochemistry test program which shows that the
residual reagents left in the effluent (without
dilution) are below the detection limits or near the
detection limit. The modelfor simulating the fate of
the residual reagents below or near the detection
limits takes into account natural degradation, and as
the reagents are not considered to be persistent or
bioaccumulating the accumulating effects are
considered to be a direct result of the concentration
at a given time.
128
See also answer no. 4 to the question raised under
the 3rd Public Hearing.
20.4 Using the limit values For example, some process additives used toxic values as limits values. In order to avoid higher concentrations of accumulation and to safety reasons, one will, at least in the case of a ride on the load of the human / animal use higher levels significantly below the toxic values. There should elaborate on how the choice of limit values is made. Proposal: Assessment behind the choice of limit values should be visible and discussed in the EIA.
The EIA does not stipulate the PNEC (potential no effect concentrations), values of various compounds, as this is to be finally declared by BMP in collaboration with DCE/GNIR on the basis of ecotoxicological testing and dilution ratio to be determined. The use of acute toxic limits in the EIA is used for illustrative purposes to compare with the modeled and evaluated concentrations mentioned in the report.
DCE/GN: Reference to 7.1. None
20.5
Specifically to the EIA:
In Figure 3.2 it is not clear what the numbers
in the figure / table refer to (annexes?)
Specifically to individual areas
Oil spills
Oil spills immediately assessed as potentially
the most serious pollution risk. Proposal: It is
because of risk of oil pollution in the inlet
system ensured that it identified the
importance of the ships' fuel type has a
In Figure 3.2 the number following an “Ω,” is shown
by example in the legend to refer to annex numbers.
As mentioned in the EIA section 7.1.8 and Annex 6,
section 7.1, the use of heavy fuel oil (HFO) has
already been banned in Antarctica and calls are for a
possible future ban in the Arctic as well, although no
date is known for such a future ban.Many ships
BMP: Requirements can be set in the government approvals. DCE/GN reccomend that oil spills are handled in the emergency contingency plan.
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129
potential contamination of the inlet system
by accident or to require that ships to and
from the mine using the fuel with the
smallest load of waste.
sailing in Greenland waters today use HFO’s
however, and any specific demands in relation to
the Isua project are a matter for the Greenland
Government.
20.6
Discharges of fresh water that is warmer
one inlet water
The project will be discharged to freshwater
(7.4 mio.ml /year) into the fjord system
which is warmer than the fjord system. It is
not clearly stated in the report; which
impact this would expected to have on the
local flora and fauna.
Proposal: It will be made clearer in the
EIA/Whitebook, the significance of the
discharge of warmer fresh water has on the
local flora and fauna and to the proposed
mitigation measures are described and their
impact assessed.
The volume of freshwater that is discharged from
the retention pond to , Taserâssuk Bay, is 7.4 million
m3/year.
This roughly equates to 20,315 m3 every 24 hours.
The area of Taserâssuk Bay is 20 ha (= 200,000 m2),
meaning that if the entire 24 hour volume of
discharged water were distributed evenly over the
bay it would be a layer about 10 cm thick compared
to a depth of water of hundreds of meters in short
distances from the port area.
Tides and winds flush most of the water volume in
and out of the bay several times a day. See also
Annex 7, sections 4.5.1, 4.5.2, 5.4.1 and 5.4.2 and
see question 20.2 above.
DCE/GN assess that the effects will be
local.
The insignificant impact of warm discharge will be added to the EIA
20.7
What consequences will the nitrogen emissions have ?
Comparisons to temperate waterways and runoff from agricultural land are meant to give an idea of
DCE/GN: Nitrogen is not adequately addressed in the EIA. There are for instance large amounts of nitrogen in
The nitrogen balance
130
The Nitrogen impacts of the water environment is indicated as low compared to the load of nitrogen in temperate regions. It is it shown if this comparison is relevant and it does not indicate what a nitrogen load of this magnitude could mean for flora and fauna locally Proposal: To be documented whether the comparison is relevant and that the local condition is make clear.
the relative sizes of the modelled nitrogen quantities. However, as the biota of Western Greenland is different from temperate regions it can also beneficial to compare the nitrogen loading caused by the Isua project to local natural and manmade sources. As stated, the estimated nitrogen load to local waterways from use of ANFO explosives and reagent residues has been calculated in the EIA to be ~280 t/year. Due to low temperatures and low productivity in local fresh water systems, it is assumed that none of this nitrogen is transformed in the fresh water aquatic environment. The nitrogen will eventually, after years of retention time in lakes along the water course, reach the Godthaabsfjord. For comparison, baseline measurements in May 2011 of Total-N in lakes along this water course (Lakes: 792, 750, 693 Imarssuaq and Taserssuaq) were in the range 0.1-0.3 mg/l. Values in this range have also been reported for many other lakes in the area /Jensen, 2012 and Jensen and Rasch, 2011/. Assuming these values to be representative for the yearly average, the nitrogen transport from the Kugssua River is (7000*106 m3/year x 0,2 g/m3) = ~1400 t/year. If the total catchment to the Godthaabsfjord is assumed to be ~3 times larger than the Kugssua River catchment area, the nitrogen load from the catchment area to the fjord is expected to be around 4000 t/year. Other sources of nitrogen are treated sewage from Nuuk, which (with ~16,000 pax and 5,5 kg N/pe/year) = ~90 t/year, and deposition of atmospheric nitrogen directly on the surface of the fjord (surface area = 2000 km2 and deposition rate 0,2 kg N/ha/year = 20 kg N/km2/year) = ~40 t/year.
blasting materials that is discharged to the tailings lake and thus further downstream to lakes and rivers. Calls for further treatment of nitrogen by LM / Orbicon.
presented in the response will be included in the EIA section 7.1.12 and in Annex 7 section 5.3.2.
131
Compared to all other sources of nitrogen to the Godthaabsfjord (total: 4000+90+40=4130 t/year), the 280 t/year input from Isua would account for a very small proportion of the total nitrogen load to the fjord.
It should also be noted that the Godthaabsfjord also contains nitrogen from inflows of coastal seawater in the form of dissolved N2 gas, nitrate, nitrite, ammonia and organic forms. The total volume of the fjord is 525 km3 and the water in the deep basins have an average residence time of 1-2 years /Mortensen et al., 2011/. This means the yearly exchange is in the order (525*109 m3/ 2 years) = 262*109 m3y-1. Measurements of nitrate/nitrite in deeper layers of the adjacent Kobbefjord during the MarineBasis Programme under NERO 2010 indicated high nutrient levels in particularly deeper waters, with a maximum of 12.3 µM (=0.17 mg/l). This means that up to 262*109 m3y-1* 1.7*10-
7tons/m3 = ~45000 t/year nitrogen moves through the Godthaabsfjord as a result of exchange with surrounding coastal waters. Considering the direct inputs of nitrogen from the catchment area and anthropogenic sources, as well at the large reservoir of oceanic nitrogen circling through the fjordsystem, it is assessed that the input of nitrogen from the Isua project will not have significant impact on the global nitrogen balance in the fjord.
20.8
Long-term effects of copper and iron
The Greenland Water Quality Guidelines for mining activities (GWQG) are specified in the guidelines for
DCE/GN: Nothing to add.
None
132
emissions? The concentration of both of these substances are by discharge to the fjord system above the indicative limit values, but it is stated that there will be a dilution within a short distance from place of discharge. This is not fully documented, and it is not analyzed or discussed the significance of this release will have over the mine life. Proposal: It proved that there is a rapid mixing and the importance of the cumulative emissions over the mine life is clarified.
EIA by BMP. The values are for ambient, not effluent, concentrations. Ambient concentrations shall not be confused with effluent concentrations. As the Kugssua River is by no means the only glacial melt water influenced river entering the Godthåbsfjord, the amount of iron and copper naturally entering the fjord every year is considered many orders of magnitude larger than the input from the retention pond. A near field dilution of 1.5 times for copper and less than 5 times for iron to reach the values of the GWQG can easily be obtained in very short distances from the discharge point. It should also be noted that in for instance the glacial melt water influenced lakes, which feed the Kugssua River, baseline measurements of dissolved copper and iron have recorded that concentrations are up about 1 µg/l and up to about 100 µg/l respectively. While slightly lower in concentration than the water leaving the retention pond (up to about 3 µg/l and 140 µg/l respectively), the Kugssua River has a yearly outflow about 1000 times larger than the retention pond. See also Answer no. 4 in Public Hearing meeting no. 3.
20.9
The combined and cumulative effect of environmental impact of process substances It is in total expected to be imported 6,056 tons of chemicals for production per month mine life of 15 years; it will be a total of 1,090,080 tons. Elimination of substance of harm to the environment in this
The numbers quoted in the question are resultant of a factual misunderstanding. The table quoted reports maximum monthly quantities and average yearly quantities. Therefore, it is planned that the actual quantity of total reagents used over the lifespan of the mine is around a third of the amount stated in the question. As to all other aspects regarding the reagents, the answers are given in 20.3 above.
DCE/GN: Nothing to add.
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133
concentration will necessarily have an environmental impact. But how big will this be? According to Annex 6 it this with regard to the following products:
See table in the following section “details descriptions”
[The table refered to can be seen in the EIA
Annex 6]
The quantities of some of these substances
will depend on the production, and there
may be need to use of other than the
products than the mentioned in production
and other chemical substances may be
contained in the products, which are
selected to be used.
Especially for substances xanthate and
amines, it will be necessary to ensure
dilution before any release to the fjord
system to reach concentrations below the
toxic dose for Daphnia.
Proposal: That the report / white paper is made visible and discussed which effects the discharge of process substances will have
134
over the mine life including combined and cumulative effects and that the same will apply if there will be other compounds other than these substances, such as process.
20.10
Where are the pollutants from the process
going?
The EIA does not present studies of flow
conditions in the fjord, only in the Qugssuk
Bay, where there was found a slow net flow
rate, large variations in salinity and
oscileating currents in the bay with the
tidewater, but also very limited mixing of
these water masses at the bottom and on 15
m depth. This means that there could be an
accumulation of pollutants in some layers,
depending on their temperature and salinity.
There is no evidence of what this may mean
for the distribution of pollutants in the fjord
system. It is not documented in the report,
how quickly fjord water is changed or the
extent to which it moves back and forth in
the bay with the tidewater. It therefore
cannot be documented. The extent to which
pollutants will be washed into the sea, will
remain in the inlet system, or on the due
flow conditions will be further concentrated
As the ADCP&CTD probe used for baseline
measurements in Qugssuk Fjord were deployed for
nearly a year, the total net flow rate is not all the
indicative of the current conditions. Currents of 0.2 -
0.6 m/s were frequently recorded in Qugssuk and
are reported elsewhere in the fjord by Mortensen et
al 2011 (Heat sources for glacial melt in a sub-Arctic
fjord (Godthåbsfjord) in contact with the Greenland
Ice Sheet) The circulatory system of the
Godthåbsfjord is, however, quite complex. At neap
tides it can be characterized as a wave fjord, and at
spring tide as a tidal jet fjord. Over the course of the
year four different types of circulation systems are
thought to occur. In summer estuarine circulation
occurs with a top layer of 5 meters deep fresh water
runs out of the fjord, and compensation current in
the layer down to 15 m depth run inwards.
In areas of the fjord next to glacial intrusions, sub
glacial circulation occurs when freshwater enters
the fjord at depth rises to the upper layers and gives
rise to vigorous mixing and entrainment of ambient
waters.
In winter dense coastal inflows occur in deeper
DCE/GN awaiting ”Amendments” in the
final EIA.
Amendment to be made to EIA, section 5.1.7 and Annex 7, section 4.5 presenting the circulatory regime in Godthåbs-fjord.
135
in some areas of the fjord system.
Proposal: It is necessary through additional
studies to document that contaminants do
not accumulate in the fjord system.
parts of fjord and raise isopycnals accordingly.
Intermediate baroclinic circulation in outer parts of
fjord can occur year round, when tidal mixing of
fresh water and saltwater cause horizontal density
gradients, which give inward currents in upper
layers and outward currents in lower layers.
In the basin waters, found in the deeper layers
between sills, the residency times are expected to
be 1-2 years. (Mortensen et al 2011.)
On this basis, it is considered that the circulatory
system in the Godthåbsfjord is quite dynamic, and
given the naturally large amounts of metals washed
out into the fjord by glacial melt water influenced
rivers, such as Kugssua, the contribution of the
effluent from the retention pond at the port area is
marginal. Also refer to the answers in 20.3 above
20.11
Waste Management
Isua will build its own incinerator. This will
require monitoring of the impact and
pollution.
Proposal: There should be control of emissions from waste incineration included in the monitoring plan. Ongoing analysis of the content of the slags from incineration should be performed prior
As mentioned in the EIA, sections 0.6.4, 4.4.6 and 4.8.1, the waste incinerator will be state-of-the-art and will have an over-capacity in relation to the expected workload. A detailed monitoring plan proposal is included in the EIA and will be further detailed by the appropriate authorities.
DCE/GN: Nothing to add.
None
136
to deposition in lake 750.
20.12 Regarding: Hearing of the SIA for lsua iron ore project for London Mining Greenland AIS
The Department of Health thank you for hearing of SIA report for lsua iron mining project. General information about the project lsua mine project will probably be Greenland's first large-scale project. The project is located at the bottom of Godthåbsfjord up of the ice cap. It consists of a transport port, a 105 km long pipeline to a processing plant - where there is a road and pipelines with water and waste water and a real mine site. In addition, the mask is being built an airstrip for small fixed-wing aircraft. The ironore will after crushing, concentration and damming be transported as liquid through the pipeline to the port where it will be stored in solid form until shipment. It will be during the construction phase almost exclusively employ Chinese labor at peak times up to 3,300 workers at a time, while in the operational phase will be employed around 800 people, with the increase in the amount of local and Western employees in the 15 year operation phase. The Chinese workers are expected to work 10 hours a day for 6 days a week. Local /
BMP: In an upcoming update of the BMP guidelines it will be considered whether these areas should be a part of the requirements in the SIA.
Section 5.5 Education will be updated.
The figures
in section
5.2.8
Mortality
and death
rate will be
updated.
137
Western employees are expected to have whole week off outside the camp. Generally regarding the SIA. This SIA is written based on the BMP's guidance on "Guidelines for Social Impact Assessments." It is an important document towards a realization of the project. Consequently, it should be correct in every detail, when it will be available for the public consultation. It is therefore unfortunate that the SIA is not fully up to date with the latest conditions on eg education, regarding laws, and contains a number of errors that could have been avoided if the relevant parties had received SIA in pre-hearing before distribution to the public. A more thoughtful of these fail, that indicates that it is clear that 2 out of 3 deaths are men. No one is immortal and birth rates for boys and girls are quite similar. It may only be a one time lag. The SIA does not cover all elements around the social effects of the project. The SIA is, as it stands, not suificient about the project's effects on the community funded sectors such as health, education and social sectors and not for the sectors such as police and judiciary (still under Denmark). Suggested solution: BMP states in its guideline about SIA that a pre-hearing of the
Section 5.5 Education will be updated.
The figures in section 5.2.8 Mortality and death rate
will be updated.
138
factual circumstances described in the SIA should be performed. BMP ensures that assessments of the impact of the project on the sectors which are financed by the society is included in the SIA and through change in the guidance sets out requirements for such an assessment included in future SIA.
20.13 From "fly in - fly out" design for transport via Nuuk and health instruction in Nuuk It is natural that projects and their design changes over time, but it is important that the project will contact the informants within relevant sectors of society, if changes occur in project design that may be of interest to them.
When the Department of Health at first heard about lsua projektet was when the project locally would establish a mini hospital with a number of doctors and nurses like an airstrip was to be built where mine staff and the sick were transported directly into / out of Greenland. Such an organization has little impact on the health situation in Greenland, as the minor effect on the capacity of health care and the risk of mutual contamination between population and mine staff is minimal. It has now opted out this organization so that mine staff will transported via Nuuk and will now only be an emergency room / lazeret without doctor and can only take care of minor injuries and provide limited
In section 6.5 Health (6.5.2.7 Health management) is stated that “Onsite medical facilities for both the construction and operational phases will be equipped and staffed to aid employee’s with minor and less serious ailments. In the event of serious illness or injury, depending on the situation, the employee will be transported by either air or sea to the nearest healthcare facility in Nuuk.”
It is important to understand that a mine can not
provide a full service medical facility. The local
hospital is expected to provide emergency services
to the serious conditions. London Mining and its
employees are paying taxes and should have the
right to use the emergency services.
London Mining will in cooperation with the Health
Auhtorities develop clear criteria and conditions for
use of local health services and asses the need for
supplementary capacity (see 6.5.3 Health Service
(SIA Report)).
- Update the section to clarify the potential impacts
139
diagnostics. This is changes of central importance to the Greenlandic health as it affects treatment in health care in Nuuk and public health. SIA has not analyzed the impact on health service of the local population and public health by these changes. Suggested solution: BMP requires that when significant changes to the project relevant parties should be involved again and heard again.
This is already a standard procedure.
20.14 The importance of the lsua project with regard to health control and public health The Department of Health believes that all who live and work in Greenland has the right to control the health care only by their needs for services and not for example on the basis of home country, but also the control of people from outsiders such as mining personnel must not be at the expense of the possibility of providing health service to local people. The current plans for Isua has or may have importance of
1) treatment,
2) health economy
3) public health including the spread of communicable / infectious diseases.
No response is required. - None
140
20.15 Treatment capacity in Nuuk The population in Nuuk is serviced by health service from Queen Ingrid Health (DIS) for outpatient and emergency services and the Queen Ingrid's Hospital (DIH) for admissions and specialist operation. DIH is also the country hospital for Greenland. DIH has already capacity problems and overcrowding and will without expansion of capacity of bed have difficulties to serve a further local population of up to 3,300 people. DIS designed with a capacity to serve the current local population. Due to the expected increased number of evacuations there can be a need for training of health care personnel. New infectious diseases (see below) may cause extra needs for isolation wards, which again creates a big demands on care and affect the ability to treat other patients.
Suggested solution: London Mining Greenland conferred upon the basis of other similar projects to analyze and estimate the need for services from the Greenland health, capacity requirements to meet these and the risk of transmission of new and multi-resistant bacteria to Greenland. This must be done in cooperation with the Self-Government including the Department of Health.
Comment is a matter for the Government of Greenland.
London Mining will in cooperation with the Health Auhtorities develop clear criteria and conditions for use of local health services and asses the need for supplementary capacity (see section 6.5.3 Health Service(SIA Report))
BMP: The Government of Greenland is already in contact with the Ministry of Health regarding some of these issues. Health issues can also be a part of the IBA negotiations or the final government approvals.
None
20.16 The impact of the economics of health care
None
141
system In other parts of Greenland, which serves 3000 people has the health care system care 2-3 doctors, nurses, other specialists, support personnel, etc. In total, the cost of this is between 23 and 25 million DDK yearly is not included in the capital expenditures or costs of operation for operation of DIH or in Denmark. Mine personnel in the working-age population can in comparison with normal population expected to have less acute and chronic morbidity, but considerably more working related disorders / injuries. Suggested solution: London Mining Greenland is required to set up insurance for all employees, covering all types of treatments and services from the Greenland health care system. In addition, mine staff have to have a health care test before entering (see also below).
All employees will have a private health insurance as stated in section 6.5.3 Health Services.
All employees will undergo a pre-employment medical check and annual medical examination as stated in 6.5.3 Health Services.
20.17 Impacts on the public health in Greenland The population of Greenland is now exposed to a relatively significant social stress, which is a consequence of the rapid development of society. This has resulted in huge social inequalities and vulnerable groups in society. Construction of mines has among indigenous populations in other countries has both positive and negative impact. The negative has for example been prostitution, abuse, tensions in society and greater social
Section 6.5.4 Public Health and quality of life describes the impact on public health and quality of life during construction and operation. The assessment including aspects as prostitutions, STIs, alcohol and substance abuse.
-
None
142
inequality. This is all aspects which have a big impact on public health, which is missing in the SIA.
Proposal for analysis and monitoring of these changes. Suggested solution: London Mining Greenland contributes financially to making a baseline population survey in Greenland in 2014 with oversampling in Nuuk area. A similar survey should be performed regularly, such as every 4 years during the mine life. The project's long-term monitoring of health indicators should be extended to include relevant indicators from survey of the public health (befolkningsundersøgelseme).
Comments noted and will be dealt with in the IBA discussions.
20.18 Impact on communicable / infectious diseases Today, the Greenlandic health care service and our Medical officer of health for Greenland do a lot in order to prevent the spread of diseases to the Greenlandic population through surveillance, early detection, vaccination and treatment, including requirements relating to such health care staff before employment in Greenland are tested for carrier status of certain bacteria.
A big immigration of mine personnel to
All employees will undergo a pre-employment medical check and annual medical examination as stated in 6.5.3 Health Services.
-
None
143
Greenland will have a risk of spread of new
bacteria and / or resistant bacteria to
Greenland. Infection with such resistant
bacteria may have catastrophic impact on
the health of the population and health
care. Preventive measures are necessary to
prevent this.
Suggested solution: All mine personnel
should be tested for communicable diseases
and carrier states and vaccination
equipment as recommended by our Medical
Officer of Health for Greenland prior to
arrival to Greenland. In addition regular
testing for infectious diseases during their
stay and a regular rnonitoring and reporting
of infectious diseases in collaboration with
the health authorities. If accumulation of
infectious diseases happens in the camp this
should immediate be reporting to health
authorities and the Medical Officer of
Health for Greenland (National Health
Service).
20.19 Recruitment and private healthcare It is set in the SIA that it is expected that the project will create or expand private health services.
The Greenlandic health care today has
Section 6.1.4 in SIA “Conflicts and synergies with other economic sectors” include a discussion of the competition of qualified workers including competition with the public sector.
-
None
144
difficulty in recruiting staff in almost all
professions (doctors, nurses,
physiotherapists, etc.). Whether an
expanded private health overall will be
positive or negative for the population
depends on where staff are recruited. If they
recruited among health personnel or if there
is no one
in the capacity of the private offers that
correspond to the increased demand, then
the net effect of the local population is
expected to be negative.
Suggested solution: Monitoring of capacity
in private health services and recruitment
for these. It is the wish of the Department of
Health that wages and employment
conditions follows the general agreement in
Greenland.
20.20 Public health actions
The SIA indicates that there will be
preventive and remedial health and
lifestyle campaigns. Furthermore, that the
conditions in the camp create good
opportunities to tackle issues with regard to
diet, lifestyle and drug abuse. These are
good initiatives, but the department
believes that campaigns are not enough.
Comments are welcome and a monitoring plan will be developed.
-
Update the monitoring plan to add the lifestyle monitoring plans.
145
Suggested solution: It is expected that the
project will ensure health care management
including an ongoing monitoring of lifestyle
and targeted intervention, as well as
targeted ensuring of abstinence in the
project.
20.21 Preparedness of the project's health care
The camp's health service will according to
the SIA be able to cover minor damage and
minor health problems. The Department of
Health's position is that the today outlined
capacity does not correspond to risks of
disease and serious accidents, which creates
the need for quick and effective treatment.
Today, the project rely on a unified system
of transportation per boat with possible
additional use of helicopter flights. Both of
these will be problematic in bad weather. All
aspects should be assessed and a ROS (risk
and vulnerability) analysis of the project
should be carried out.
Suggested solution: A ROS analysis should be
carried out of the needs of health which
should be included in the planning of the
project’s contingency. In addition, a
continuous monitoring of areas defined as
risk and vulnerability should be include
ensuring monitoring and ensuring ongoing
Comments are welcome and LM will develop the suggested plans.
-
None
146
statistics on accidents and diseases among
workers at the project and that such
information is submitted to BMP and
partners such as the Department of Health.
It should be required that the staff has the
necessary training so that they can assess
and treat serious injuries / illnesses and treat
them throughout the period before transfer
can be effected. The project should, on the
basis of ROS analysis and knowledge from
other projects - enter into a dialogue with
the Department of Health with regard to
Health service with regard to need for health
service in order to balance expectations
about local health services. The project
should conclude a cooperation agreement
on health service with the Department of
Health.
20.22 Need for services from public agencies and institutions As stated above the SIA does not rely on any public bodies and institutions, while there is an on-going claim by the licensees for discounts in tax payments. Basically, the ideology behind a welfare system as the Greenlandic is that it is liable. Thus, those who can pay through the tax system will ensure those who cannot. Currently, it is not fully understood how the lsua project will draw on the resources of public authorities such as social services, health
The comment is taken into account. The pressure on the health sector should be included section 6.3 Public services and development plans.
BMP: The Greenland Selfrule has initiated a cross departemental working group where all ambiguities and questions of interpretation can be clarified
A sub section on the pressure on the public health service will be added to section 6.3 Public services and develop-
147
and education - and the areas which are under Denmark. Part of the reason for this shortcoming is that there are still uncertainties about the interpretation of laws and regulations about such right to free health service, social services and certain other public services.
Suggested solution: The project must ensure that its impact on public services and the need for additional capacity in the public sector during construction and operation is fully clarified. BMP must initiate that all unclearness and questions of interpretation about what rights Isua employees from outside has to publicly funded services in Greenland. Any reduction in tax must await this clarification.
ment plans.
20.23 Monitoring of health personal and grievance
of healtcare personal in Greenland will be
monitored by the Medical Officer of health
of Greenland to ensure the service lives up
to good professional standards. The people
have the opportunity to complain
of health care, if they do not believe that it
lives up to good professional standards.
These rights are not guaranteed for current
employees for at lsuaprojektet.
Suggested solution: Employees at the lsuaproject, in cooperation with relevant partners on Self-Government must be
Comment is a matter for the Government of Greenland.
BMP: requirements can be set in the government approvals or be a part of the IBA negotiations.
None
149
21. Nuuk Fjords Venner
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA
21.1
Nuuk Fjord’s Friends does not think that the public consultation on London Mining has been carried out correctly. If the public EIA / SIA consultation had been carried out correctly the people should have been involved in the EIA / SIA process already in the scoping phase, where it is extremely important to involve the public to form the EIA. This should have happened 4-5 years ago, so since 2007-8. This has completely skipped from home government / self-government side.
Then the public should have been involved
in various stages of the study of
environmental impacts. This has also been
completely overlooked by the home
governments’ and self-governments’ side.
This step is otherwise extremely important
in the democratic process of public
involvement.
Comment is a matter for the Greenland
Government.
BMP: The hearing review process is continuously evaluated in order to improve this process. Comment referring to the process is noted.
None
150
When scoping and EIA study of
environmental impacts is over, these should
have been communicated to the public.
When those are over, there must be a
review of the EIA study. This process was
made in four phases in Nuuk and only in
Nuuk, and the overall hearing lasted only 12
hours! There should only be used 12 hours
to evaluate an EIA / SIA report of 8.000
pages.
21.2 The ideal EIA process should thus have been made in the following phases: 1. Screening / EIA 2. Scoping / EIA 3. Study of environmental impacts / 4. Communication 5. Evaluation of the EIA-study 6. Project Approval / 7. Monitoring / Thus, the public has been excluded in the first, second and third process and the public were not involved until the fifth process. It is simply outrageous that this can be done - it just shows the civil servants’ and politicians’ (Government) little interest in the participation of the population. In the 7 stages, people have only been involved in one process. It is unheard that this can be done and what will our government and politicians do about this?
Comment is a matter for the Government of Greenland.
BMP: The hearing review process is continuously evaluated in order to improve this process. Comment referring to the process is noted
None
151
21.3 In the Self Government's own guidelines on EIA is following to read: About citizen involvement in BMP guideline for the preparation of EIA (EIA) (http://www.bmp.gl/images/stories/minerals/EIA_guidelines_mining.pdf) Public Hearing (Public consultation) (p. 8): "The public should be involved throughout the EIA process and be informed of the activities taking place while the mine is in operation. A public meeting at an early stage of the process to provide input to the EIA report is recommended as a minimum. A public meeting with relevant information on the EIA report and the input that has been, is also recommended as a minimum, before the report is submitted to the authorities."
Comment is a matter for the Government of Greenland.
BMP: The hearing review process is continuously evaluated in order to improve this process. Comment referring to the process is noted
None
21.4 White Paper (White Paper) (p. 8): "Clear rules and procedures in relation to citizen involvement must be described in a white paper and must contain objections and comments to the project. The White Paper is a document containing public comments, or a summary of these. It shall also include the company’s comments to the received questions and suggestions for how these issues sought clarified and addressed in the EIA process, or an objective justification for why these will not be included in the report. The White Paper contains comments / questions and the company’s answers to these should be
Comment is a matter for the Government of Greenland.
BMP: The hearing review process is continuously evaluated in order to improve this process. Comment referring to the process is noted
None
152
available in a separate document. After the citizen involvement has taken place, the EIA report should be revised and comments / questions, as well as the company’s response to these, incorporated into the final version to be dealt authority. All objections, comments, etc. can be published. Publicity phase, the minimum period of six weeks. " Timeline for the EIA report 1. Public meeting to collect input to the EIA report. 2. List of proposed content of the EIA report has to be submitted to the RD. 3. RD assesses the content list. 4. A draft of the EIA report sent to the RD. 5. RD assesses EIA report draft. 6. The EIA report is sent to RD. 7. Public hearing / public meeting on the EIA report. 8. EIA report has to be published for public consultation. 9. Consultation responses from the public stage have to be assessed and EIA report revised. 10. The final EIA report submitted to the RD for approval of the mining project. Nuuk Fjord’s Friends therefore believes that our Government is therefore violating its own rules on EIA process.
21.5 The signed person requested in 2008 on material for field report which at that time already existed. But this was flatly rejected
Comment is a matter for the Government of Greenland.
BMP: A Field Report is not a part of the EIA. A Field Report is a short technical report listing for example a short
None
153
by mining directorate and where I just was referred to London Mining - but this was also rejected by the company. It is such reports which should have been promoted in the above EIA process 3rd phase of the EIA study of environmental impacts. This is just to demonstrate that our claim to the EIA phase has never been implemented.
description of the activities, material temporally left in the field, personnel employed and similar issues. A Field Report form can be found on: http://bmp.gl/minerals/application-and-reporting-forms
21.6 We will refer to a report from Aarhus University on EIA and the public, which included are the following: "Democracy Public participation is based on the democratic ideal of the public to be present in the decision-making processes. Public participation tries to maintain the democratic ethics: political decisions must be public, democratic practice is revitalized through public participation, and this helps to ensure the citizens' interests. When the public is involved early and properly in the EIA process, citizens can influence both the planning process and on the final result. Public participation in EIA processes thus gives citizens a sense that they have an impact on their local community. This makes them responsible democratic citizens, and simply confirms democracy. It is even believed that public participation in EIA is not only desirable but simply necessary in a democratic society. It is important for the process of the
Comment is a matter for the Government of Greenland.
BMP: Noted. DCE/GN: This is not an environmental aspect.
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154
planning that the negotiations between the client and all who have an interest in the case are held in a democratic and honest spirit. The client may attempt to minimize public participation as much as possible, based on the assumption that public participation will delay and thereby increase the cost of the project and create resistance in the population. But on the contrary can the negotiations with stakeholders can avert the opposition that otherwise might be overtaken by citizens who felt that their bourgeois democratic rights were ignored. "
21.7
Nuuk Fjord’s Friends believes that the studies of EIA / SIA are incomplete and superficial prepared by Orbicon and Grontmij.
Comment is a matter for the Government of Greenland.
BMP: It is the opinion of the BMP that the submitted EIA and SIA reports including the hearing review comments added are in accordance with the requirements in The Minerals Act. The National Centre for Environment and Energy (DCE) is guiding the BMP in environmental and EIA related issues. If the DCE point out areas that require further investigaton, this will be a requirement.
DCE/GN assesses overall, that the EIA report gives a comprehensive picture of the project's environmental impacts.
None
155
22. Janus Kleist
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA
22.1 On the London Mining web side the following regarding sustainability can be read:
"We are looking to the future and how we
will live and work together with the
communities and organisations around our
operations now and in the years ahead. We
recognise the importance of exploring fully
all the options that will enable us to meet
our long term responsibility for our
resources and surroundings. This genuine
commitment to sustainability is a key part
of the way we will contribute, endure and
prosper."½
In the "Act of Inatsisartut on Mineral Resources and Activities (Mining Act)" it says in § 1:
"By inatsisartutloven seek an appropriate exploitation of mineral resources and the use of subsoil for storage or purposes relating to mineral resource activities and regulation of matters of importance to mining activities and underground activities.
Comments noted.
- None
156
Paragraph.2 By inatsisartutloven aim for the
activities covered by the Act that they are
performed securely in terms of safety,
health, environment, resource utilization
and social sustainability as well as
appropriate and in accordance with, under
similar circumstances, recognized
international best practices. "
22.2
Finally, I understand that London Mining will seek China Development Bank (CDB) to become an investor in the Isua project. CDB write on their web pages (http://www.cdb.com.cn/english/NewsInfo.asp?NewsId=4161) on sustainable development:
“A Sustainable Development Initiative was
issued today at the eighth Council meeting
of the Shanghai Cooperation Organization
(SCO) Interbank Association in Beijing,
calling on member banks to strengthen
financial cooperation and advance the
cause of corporate social responsibility
and "green" economic growth. The
initiative represents a joint commitment
by the six member banks of the SCO
Interbank Association: China Development
Bank (CDB), Kazakhstan Bank of
At this stage it is stil unknown who will be the
investor(s) that provide funding for the Isua project.
However, practically all potential investors that
would consider supporting a modern large-scale
mine project such as the Isua project, will make it a
requirement that the project use state of the art
technology, is implemented in the most
environmentally friendly way and is socially
responsible.
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157
Development, the Settlement and Savings
Company of Kyrgyzstan, Amonatbonk of
Tajikistan, Russia's Vnesheconombank,
and the National Bank for Foreign
Economic Activity of Uzbekistan.
On the basis of the SCO Charter and the SCO Interbank Association Cooperative Agreement, the initiative requires member banks to strengthen cooperation in the field of sustainable development. Member banks are urged to:
1.Develop financing mechanisms and
methods of sustainable development that
reflect the diverse conditions and needs of
each SCO member state.
2.Utilize financing support to promote
cooperation on large projects that spur
regional development in the economy,
society, and environment.
3.Provide priority support for industry, agriculture, environment, public services, and infrastructure (including the transportation, building/construction, and energy sectors).
4.Maintain close cooperation in the field of energy, with the goal of securing sustainable energy resources.
5.Strengthen financial cooperation in
support of underdeveloped regions, remote
158
populations, and SMEs.
6.Fully recognize the importance of the
"green economy" in the quest for
sustainable development, especially in
terms of economic rebalancing, climate
change, and public well-being.
7.Adhere to international protocols and norms governing corporate social responsibility, establish effective CSR management systems, and contribute to the field by sharing experience and know-how.
8.Affirm that sustainable development is the common aspiration and responsibility of all nations, and requires the broad, deep participation of government, civil society, and the private sector. Clients and stakeholders are called upon to join together in meeting this task and make new contributions to sustainable development.
22.3
With the above in mind, I wish with this letter to London Mining and Greenland Self Government to stress the importance of using hydropower for the Isua project or a combination of a (small) diesel generator (if absolutely necessary) and hydropower. If CDB wants to be a serious, credible and long-term investor in Greenland and the Arctic, it should be possible to emphasize to
It should be recalled that London Mining does not
have the right to use the water resources in the
project area. In spite of this London Mining has
requested the International Engineering firm SNC-
Lavalin to study the feasibility of hydropower for
the Isua project. The conclusion is that hydropower
is not feasible (see the answer in 5.1 ).
BMP: Noted.
None
159
them that their investment should be a lengthy and as sustainableas possible and that they therefore cannot expect a quick return, but instead must expect a longer and more sustainable returns through the use of hydropower. If Alcoa takes their plans off the table the Self Government should open a door for London Mining to immediately begin to build a hydropower plant for the Isua project.
160
23. Arbejdstilsynet
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA
23.1 Under the legal framework (s 31 -33) may it be considered to refer to several relevant regulations within the Working Environment Act. For example: a review of occupational injuries and work-related accidents, rest periods and rest days, asbestos, occupational and safety educations. Furthermore, it should be considered to add the rules as young people under 18 years can not work at mines.
Comment will be taken into account -
Additional
regulation
will be
added under
the working
environment
act.
23.2 On page 128 is outlined electrical work schedule that does not comply with the OSH Act, rest periods in Greenland. After the Working Environment Act § 41 employees must be given a weekly day off. Therefore it can not be plan with 3 shifts based on 12 hours a day, 7 days a week for 6 weeks and then 3 weeks off. It is possible that an agreement can be established to work 12 days in a row and then have 2 days off.
London Mining will follow the Greenlandic Act, and rely on Government advise in the matter of work shedules based on rotations.
-
None
23.3 The section on training (p 154) lacks the education on safety training for safety representatives. Greenland Self-government supports the introduction of a special training for coordinators of health and safety work in construction.
Comment will be taken into account
-
Education for safety representatives on safety training will be added.
161
23.4 In relation to the chemistry field (p 1 75) is stated an information system on hazardous materials at work and suppliers manual. The attention should be given to the requirement of an employer manual.
Comment will be taken into account
-
Comment will be included
23.5 In relation to workers' obligations it is states that it is the employee's responsibility to ensure that they are equipped with all necessary personal protective equipment and they are responsible for the provision of personal protective equipment (p 175). Attention may be drawn to the Greenland act on working environment and the requirements to the employer.
Comment will be taken into account
-
Comment will be included
23.6 In the final table with list of impacts, etc. indicates (s 205) that: "The risk of accidents at work are linked primary to the employees behavior / attitude to their work" and existing mitigation measures are listed (Greenland Working Environment Act) and proposed measures such as implementation of safety and health plans. Experience shows that other aspects than the workers relation to safety is often the underlying cause of accidents, such as lack of instruction or lack of maintenance of equipment.
Comment will be taken into account
-
Comment
will be
included
162
24. KANUKOKA
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to SIA/EIA
24.0 KANUKOKA appreciate the submitted consultation material regarding London Mining’s application for exploitation of iron presence at Isua in the bottom of Godthåbsfjord. The material includes as prescribed in the Mineral Resources Act an assessment of the environmental impact of the project (EIA) and an assessment of the project's social sustainability (SIA). The material and the ongoing consultation process which gives rise to a number of general comments, as presented initially. Then the contents of the respectively EIA and SIA statements are commented separately.
The response was prepared by the Local Joint Mining Group and KANUKOKA. KANUKOKA and the municipalities generally welcome the economic progress such a mining project is likely to have for the municipalities. The project is expected to have an overall positive effect on the local economy. This is caused by the mine itself but also due to the development of the local business community which is expected to increase in activity and thus have a positive effect on employment. Such a large mining project will boost the development of new
No comments required from London Mining to the introduction.
-
None
163
economic activities in Greenland.
It is expected that Kommuneqarfik Sermersooq will have increased operating expenses because of the large project. It would therefore be appropriate that the municipality receives a share of the gross tax, as agreed between Naalakkersuisut and KANUKOKA. General Comments Public meetings - consultation process Both BMP and London Mining have made great efforts to inform the public about the project, and KANUKOKA welcomes the initiative to engage an independent facilitator to organize the public meetings. The arrangement of the meetings is debatable, but BMP should generally be applauded for trying out different methods for involving the public. Despite the many initiatives the population has generally expressed great dissatisfaction with the consultation process. There is obviously a need to make it clearer to people how they can have influence during the hearing process. It is important that this process is thoroughly evaluated and the criticism raised is taken serious and that the way the hearing process is carried out is modified on the basis of the experience that has been gained. KANUKOKA is happy to contribute to this process.
BMP: Public meetings and allocated time for the consultation process will be evaluated continuously in order to have this process more stream lined and improved.
164
A major point of criticism has been the length of the consultation process. KANUKOKAs believes that in connection with future large- scale projects more time should be allocated for the consultation process, which obviously will include large and complex documents. It is totally reprehensible that some technical annex to the EIA report has not been publicly available from the start of the consultation process. This should after KANUKOKAs view automatically lead to an extension of the consultation period. Specifically, KANUKOKA suggests that the non-technical summaries are made more accessible. This could for example be done by making them available at municipality and village offices, libraries and other public places, along with a number of key reports with Annex for review / borrowing.
BMP: To the best knowledge of the BMP the relevant reports have been available from the public library in Nuuk.
24.1
Notes to SIA report KANUKOKA believes that the education plan should be more targeted and more ambitious. The proposed number of apprentices is too low, especially in the beginning. There is a need for a major effort in order for the chances to be proper for the local workforce to be qualified for the new tasks early in the extraction phase and thus be more active in the mine. We also need better description of the efforts regarding
Comments are noted. This will be an important topic
in the upcoming IBA negotiations.
-
None
165
upgrading linguistic skills for apprentices. KANUKOKA expect that the large-scale project will to a large extent be able to attract labor and suppliers from the rest of Greenland. During mitigation measures, actions that promote the role of the Greenlandic businesses as subcontractors for the project should be implemented throughout Greenland. Furthermore, information campaigns should also be directed towards Piareersarfiit and Labour Offices in the rest of the country on the needed skills of the employees.
This will be an important topic in the IBA.
For each section:
24.2 To 1.2.2. The material shows that Sisimiut is the southernmost place in Greenland where it is legal to keep dogs. This is not true as there are other limitations on the East Coast.
Comment will be taken into account.
-
Page 28 of
327: In
Sisimiut, it is
possible to
have dogs
(the
southern-
most area in
West
Greenland,
where it is
legal).
24.3 To 2.2.1. The material says "Safety at Sea Act # 882". The correct term is Maritime Safety Act No. 882.
Comment will be taken into account.
-
‘Sikkerhed til søs’ is the correct Danish term.
166
24.4 Ancient relics, finds, monuments, buildings are not regulated by the Nature Protection Act but by the Act of Inatsisartut # 11 of 19 May 2010 on the conservation and other heritage protection of cultural relics.
Comment will be taken into account. - Reference will be made to Act of Inatsisartut # 11 of 19 May 2010
24.5 Nature Protection Act is from 2003 and not as stated in 2007.
Comment will be taken into account. - Reference will be made to 2003.
24.6 It is noted that the field rules of the BMP are not mentioned in the list of guidelines relevant to the project.
Comment will be taken into account. DCE/GN: Nothing to add. The field rules will be added to the list in chapter 2. Policy, Legal and admini-strative framework
24.7 To 3.2. The description is lacking what will be left out during the process (sorted ore (tailings), water, etc.) from "grinding" until loading ships, and possibly further treatment of what has been left out.
After mining operations, the remaining materials include tailings and waste rocks. The tailings will be safely deposited in a glacier lake with a permanent water cover and the waste rock will be stockpiled in a designated area. No long term environmental issues are identified for both facilities. These are discussed in detail in the EIA report.
DCE/GN: Nothing to add. None
24.8 To 5.3.2.
It is noted that there are two minor errors in the list of KANUKOKA's work. In one place it says "Social Affairs and Health" and the second "Building Construction and Environment". The correct names are "Social and Human Life" and "Technology and the
Comment will be taken into account
-
To 5.3.2. "Social and Human Life" and "Technology and the Environment".
167
Environment".
24.9 In § 5.5 There are some serious factual faults on page 87-90: As it appears, that the vocational education only run regular training. Maritime School in Paamiut (maritime safety) and Language Center is forgotten in the statement. - All trade schools runs further/supplementary training and courses for mainly unskilled PKU and AMA - There is no mention of further/supplementary training as a common core and mine courses, but only arctic engineer. - A prerequisite for participating in the training at the mining school is good English skills. The Language school in Sisimiut runs language courses, including mining and off shore English. Among the unskilled workers in Greenland there are many who have participated in one or more further/supplementary training courses. This acquired knowledge can through the ‘Realkompetenceprojektet (a public project on competences) be turned into regular competences.
The comment will be taken into account
-
It will be clarified that the vocational education also offers further/supplementary education. Furthermore, will the Maritime and the Language schools be added to the list.
24.10 To 6.2.2. KANUKOKA believes that the establishment of a training center will be a good approach in the project and should be established as early as possible.
No response is required
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None
168
To 6.7.3. and 7.1. It seems misleading that in 6.7.3. some impact categories is written "no action required", but in 7.1. A list of measures proposed within the same impact category. We also need a brief justification for each impact category which is not mitigated.
Comment will be taken into account
-
The use of the term “no action required” will be explained further and why some impact categories will not be mitigated on project level.
24.11 To 7.1. KANUKOKA recommends that under the section "Occupation (directly under the construction phase)" to be added "Proposed action": - To promote the use of local labor trained local foremen of the so-called trainee programs - To prepare for the project massive linguistic upgrading English courses to be established by the Language School.
Comment will be taken into account.
-
Proposal by KANOKOKA will be added to section 7.1
Comments on the EIA report
24.12
The Assessment of Environmental Impact (EIA report) consists, in addition to the main report, of a number of Annexes and a non-technical summary. The Annexes are not commented separately, but the information in the relevant Annexes is included in the assessment of the individual elements in the main report.
No response required
-
None
169
24.13 Non-Technical Summary The language and the content of the non-technical summary appear admirably clear and thorough, with good explanations that with very few exceptions, and are adapted to a non-technical audience. Concrete information on quantities and ingredients are missing with regard to discharges to sea and freshwater environment as examples. The map and image material which is referred to should be inserted directly into the non-technical summary, so the summary can stand alone and be read independently of the main report. Although it is not a formal requirement, it would be a good idea (as well?) to make the non-technical summary available as a separate document. There should be made references to specific sections in the main report where you can find detailed information on each topic. In section 0.1., the next to last paragraph, the working conditions of "Greenlandic" and "Western" employees are mentioned. Conditions for "non-Western" should also be provided to give a real picture of the situation as non-Western employees will form a significant part of the workforce also in the operational phase.
The general comment on the Non-technical
summary acknowledged
A summary has by nature to be short and concise.
This means that only the most essential information
is included. For this reason we have not included
quantities and ingredients in this part of the EIA.
Maps and pictures are deliberately not included in
order to keep the summary short and concise.
However, we agree that key maps and images
should be included if the summary should be used as
a stand-alone document. For the time being the
summary is included in the main report.
Again, this approach was not taken to keep the
summary as short as possible. The table of contents
will guide the reader to the relevant sections.
Regarding the conditions for ‘non-western’ workers
will be amended to the existing text in the EIA based
on information from the SIA report.
DCE/GN: Nothing to add.
The non
technical
summary
section 0.1
amended
with
information
re. ‘non-
western’
workers
170
24.14 The main report The main report begins with a description of the project design, which generally gives a comprehensive overview of the project elements and design. Section 4.4.7 p.81 At the initial public meetings organized by London Mining, some citizens asked to the effect of the expected large wake waves generated by the passage of the large vessels that's going to serve the mine. Concern was expressed on whether there could lead to dangerous situations for people staying on the beach, in the colonial harbor as an example, if large waves without notice washes over the beach. London Mining / the EIA should address this issue, and if the assessment demonstrates a need for it, the EIA should describe appropriate measures to mitigate the possible problems. Section 4.8.3. p.88 Fuel Storage and Handling: a description of the handling of accidents involving trucks or tank cars on the road is missing.
All vessels bound for the project port in Godthåbsfjord must comply with a set of navigational safety procedures set out by the Greenland authorities. This includes the speed allowed in the fjord which will be in the order of 10 knots. Such low speed should eliminate any problems with wake waves from the vessels. Spills of chemicals and oily products under transport are mentioned in Annex 6, sections 6.1 and 8.2. more detailed descriptions of handling of truck or tank truck accidents is to be part of the Environmental Management Plan (EMP) for construction. See EIA Annex 10 about EMP.
-
None
24.15 Generally about descriptions of alternatives - section 4.11: An important element of an EIA report are descriptions of possible alternatives to the solutions, and the company's reasons to prioritize the solutions. Descriptions of the alternatives are important and would give
Finding the most environmental solution is an integrated part of designing a modern mine. This includes the location mine facilities where potential impacts on terrestrial, freshwater and marine environment are taken into consideration. The EIA
DCE/GN: Nothing to add.
None
171
decision makers the opportunity to assess whether the company has chosen the most environmentally friendly alternatives, and / or the alternatives are from political decision makers' assessment the most desirable compared to an overall assessment. This element is not covered sufficient in the report. Section 4.11 contains only a few descriptions of alternative solutions. Examples 4.11.2. Mine site alternatives: Parameters, as for example stripping ratio, refers only to the selected alternative, nothing is said about differences in the environmental consequences of the two alternatives. Other parameters are discussed only superficially and do not include a comparison of the two alternatives. 4.11.3. Alternative locations of the plant: The reasons for the selected alternative are mentioned, however, no alternatives are described. 4.11.4. Technological alternatives: The case for the selected alternative is mentioned, but no alternative are described. For designating of the location of the port, and choice of energy source is given a good overview of the considerations that were made and the basis for the final decision. In the descriptions of key elements to the design of mine, the choice of transport
team has taken an active part in this process. For example was the design of the road-pipeline alignment modified to include ramps to make it easier for wildlife to pass the pipeline. The EIA Team was also part of the design of the stacks at the power plants in order to insure that air quality limits are met. In some situations the choice of a particular solution is a precondition for the entire mine project to be technically and/or economically feasible. This includes the transportation of the mineral concentrate to the port where it is proposed to transport the concentrate as a slurrythrough a pipeline. Alternatives such as using trucks or building a railway would not be technically or economically possible and were therefore ruled out at an early stage. In this case there are no real alternative to the pipeline. This also applies to the processing of the iron ore at Isua, that is the crushing and magnetic extraction of the iron, which follows a standard technique used in iron ore mine all over the World. In the EIA report the discussion of alternatives is limited to situations where there are options and they differ significantly in their impact on the environment. This includes the port location with the associated alignment of the road-pipeline to the mine pit. In other situations such the location for mine facilities at the mine site, the alternatives differ only marginally as far as the impact on the environment is concerned. In these situations the alternatives are not discussed.
172
solutions for ore, the road, etc. are the alternatives rejected largely without argument, and without a proper description of the possible alternatives.
24.16 Several times during the consultation process has it been mentioned that the mine life may be extended beyond the 15 years. The environmental consequences of such an extension are nowhere addressed in the EIA report. It is anticipated that such an extension will have a significant impact on the project's environmental impact, and it is therefore highly open to criticism that this is not included as an item in the assessment. For example are the calculations and the environmental assessment of the proposed tailings deposit in Lake 750 only based on a planned operation phase of 15 years. An assessment of the impact of an extended period of operation will have on disposal of tailings is missing. Is there capacity in Lake 750 for tailings from an extended operation period, and if not, how will tailings be managed if the mine life gets extended?
The BFS design is for a mine life of 10 years with a production of 15 Mtpa based on indicated resources proven by drilling. The BFS also has a design for 15 years mine life with a production of 15Mtpa, since the inferred resources are expected to be converted into indicated resources based on some additional drilling. The assumption in the BFS is based on international recognized methods to estimate the indicated resources that have to be used for financing purposes (so-called JORC codes). The London Mining expectations are that the iron resource estimate can be upgraded to 15 years of mine life with a production of 15 Mtpa upon some additional exploration drilling. The assumption of 15 years mine life of 15 Mtpa has been the basis for the EIA. If the mine life is extended beyond the assumption for the approval the conditions shall be reassessed including assessment of the capacity of the tailings lake and a number of other conditions. Since there is no actual plans and no application for such a production this aspect is outside the scope of the EIA.
DCE/GN notes that the EIA is valid only for 15 years. If the company wants to extend the production period, preparation of a supplementary EIA shoulde be commenced in good time.
None
24.17 The energy supply to the mine has been a major topic in the discussion of the project. However, it is surprising that the available details of a hydropower potential does not match what is found in connection with
London Mining does not have the right to use the hydropower potential in the project area. In spite of this, LM requested the International Engineering firm SNC-Lavalin to study the hydropower alternatives for the Isua project. This study
DCE/GN: Nothing to add. None
173
Alcoa's extensive feasibility studies for the possible aluminum smelter, and it is reprehensible that the EIA is not based on this available material.
concluded that the secure hydropower is 120 MW. LM is not aware how Alcoa made their calculation of the hydropower resources. Also refer to answer in 5.1.
24.18 Chapter 5 describes the existing environment in the area. There is no analysis of the water quality in the sea, which should serve as recipient for the wastewater discharged from the project.
Comprehensive baseline investigations have been carried out in the period 2008 – 2011. The program has been prepared upon request by BMP and in consultation with DCE. The results are summarized in the EIA (main report and Annex 7). The investigations include marine hydrography survey (one year of continuous measurements of currents in three depths, water level readings), selected water quality parameters (continuous measurements in three depths of conductivity/salinity, temperature), bathymetry survey, geo-morphology survey, marine sediment sampling, marine flora sampling (e.g. bladder wrack), marine fauna sampling (e.g. blue mussels), sampling of fish species (short-spine sea sculpin, arctic char), and video surveys in 19 coastal transects. Selected samples of flora, fauna and fish species are stored at DCE for later comparative analysis of e.g. metals or other relevant components. All baseline investigations have been used to characterize the water quality. In term of additional chemical parameters (metals in water) reference is made to typical values found by DCE in Greenland Fjord as summarized by DCE in the EIA guideline.
DCE/GN: Reference to answer 7.1. None
24.19 Section 5.1.4. The section on the hydrological system does not mention the risk of discharge of sub-glacial lakes and glacier-surge and possible
Yes, the risk has been carefully considered in the Bankable Feasibility Study. Since sub-glacial lakes discharging large volumes of water over short time
DCE/GN: Nothing to add.
The conclusion from the BFS
174
consequences of such an event. Has this risk been assessed?
could pose a threat to the mining operation this phenomena have been assessed as part of a comprehensive glacier management study which is part of the BFS (Appendix K, doc 505076-1000-4GER-0002; no. of pages:1061). The conclusion is that there is practically no potential for glacier melt water lakes discharging to the open pit. The conclusion is based on rationales of the structures in the catchment area and the sub-glacier topography, etc. The question and conclusion could be relevant to address in the EIA report.
study to be included in the EIA report section5.1.4.
24.20 Section 5.3.1. The precise location of rare plants should be marked on a map, so it can be assessed whether adequate consideration for protection is made, so any accidental damage can be avoided.
It is correct that the exact localities of rare plants are not shown in the EIA. This also applies to the nesting site of Gyr falcon. This is done in agreement with DCE to avoid disturbance of the rare species by collectors. However, the sites will be well-known to the environmental officer who will advise the engineering companies during the construction phase. There will be no conflict between the road alignment and the location of rare species. Additional vegetation surveys was carried out with DCE in August 2012 along the alignment of the access road.
DCE/GN: Refers to DCE's reporting to BMP on vegetation and botanical interests in the project area.
None
24.21 Section 5.3.7. concerning seabird colonies should be deepened. The assessment of the possible impact of the project is very superficial, and not enough to be a genuine assessment of whether the impact is acceptable.
LM agrees that the text in the main report is condensed. More information on the seabird colonies in Godthåbsfjord are presented in Annex 3. The assessment (in section 6.2.3) points out that since ships to the project port will move at slow speed and keep to the central part of the fjord 2-3 km from the colonies the disturbance will be low.
DCE/GN: Nothing to add – reference to document with proposal for environmental monitoring and environmental studies, February 2013.
None
175
The project will not discharge substances to the fjord that can impact the food resources of the sea birds.
The central chapters in the report are Chapter 6 and 7 that describes the anticipated environmental effects of the project.
No response required -
24.22 Section 6.3.3. It is positive that the Greenland National Museum and Archives has surveyed the area of ancient monuments. The report shows that the mining company has a duty to report any findings. Since ancient monuments in Greenland may be difficult to recognize, it should be considered whether some employees should be trained specifically to recognize these relics.
The point is noted.
- None
24.23 Description of residues from the processes is missing in flow charts.
The overall project is described in Section 4 of the EIA report.
Detailed process description is presented in section 4.3.1 of the EIA report including a detailed process flow diagram explaining the entire flow from the ore to the product delivery to ships.
Residues will mainly be confined in the tailing that will be deposited in the tailings pond.
- None
24.24 Section 7.1.1. KANUKOKA does not agree with the classification of the change of the landscape as a long-term impact of low significance. The prerequisite for this classification is that there will not be people in the area. The development of the ice sheet in recent years will likely mean that the ice edge will withdraw and not cover the
The detailed glaciological studies and modeling of the actual conditions and sub-glacial topography carried out as part of the BFS demonstrate that the flow of ice (ice creeping) towards the pit will continue after the mining has terminated. The horizontal speed of the glacier movement indicates that the pit will be filled with the progressing ice after a few decades. The infilling processes can also
DCE/GN: Nothing to add. Correction of the impact matrix (section 7.1.1) in the Danish translation.
176
hole - so that it will remain as a permanent scar in the landscape and on the access road, access to the area after activity will be less. It surprises also how the reference to the geographical distribution changes from regional to local, since there are no suggested mitigation measures.
be helped by the freezing of some of the melt water.
The spatial extent of the landscape alteration is
assessed as “regional” with and without mitigation
in the EIA in the English version (original) but an
error is included in the Danish translation (the
Greenlandic translation is correct).
24.25 Section 7.1.5. In the section on waste management a description of the control system for waste is missing. The control system will ensure that waste is managed in an environmentally sound manner and that the incineration slag as specified does not contain contaminants. It is not clear whether there will be established treatment of flue gas from the incinerator, but it is assumed that this will be required in connection with the approval of the plant, so it complies with the principles of the use of BAT. The Greenlandic municipalities have entered into an agreement with the facility MOKANA in Aalborg which receive all hazardous waste from Greenland and correspondingly all local authorities are also obliged to send hazardous waste to MOKANA. The cooperation with MOKANA has been extremely beneficial to Greenland, so KANUKOKA would therefore recommend that London Mining is encouraged also to use MOKANA so that waste is managed in an environmentally sound manner.
The final monitoring program which will include a suite of control parameters regarding waste will be developed in a co-operation with London Mining and the Greenland authorities. Such a control program will include monitoring of waste water, incinerator slag and other relevant parameters. This is also part of the Environmental Management Plan framework –EMP which is presented in Annex 10 of the EIA. An agreement will also be entered regarding the handling of hazardous waste. In that respect an agreement with MOKANA is definitely an option that will be considered carefully.
DCE/GN: Nothing to add. None
177
24.26 Section 7.1.7. An assessment of how light, heat and radiation will affect the area's wildlife, especially at night is missing.
Light, heat and radiation have been assessed in relation to humans in EIA section 7.1.7 and section 8.2.7. The assessment will be amended and include wildlife in the area.
DCE/GN: Nothing to add. EIA Section 7.1.7 and 8.2.7 extended
24.27 Section 7.1.8. Generally, it is the opinion of KANUKOKA that the DCE's recommendations should be followed. A significant environmental impact from the project is the significant increase in Greenland's CO2 emissions. The EIA is lacking a description and an assessment of the consequences of this release both environmentally and economically for Greenland. In spite of the existence of several technological that can potentially reduce emissions; no suggestions for mitigations are described. The consequences of any such mitigation on the environmental profile are also lacking.
The viewpoint is noted. The impact of CO2 emissions in terms of global heating is very well described in the numerous UN reports from the IPCC – Intergovernmental Panel on Climate Changes, and the main conclusion should be well known for all professionals and politicians. Lengthy text on climate changes are deliberately not included in the EIA since no additional conclusions can be added to the IPCC assessments. A reference to the latest relevant IPCC report shall be included in the EIA. The most significant source of CO2 emission is the diesel power plant. Please refer to the answer to question 5.1 .Other major sources are trucks and mining machines. When deciding the make and type of these, low fuel consumption is of paramount importance.
-
References to IPCC to be included in the EIA
24.28 Section 7.1.12. An important prerequisite for the conclusions regarding (lack of) effects of the substances discharged into the aquatic environment is that there is a rapid and significant mixing of the substances discharged. This assumption however is
Reference is made to reply 20.10. DCE/GN: Nothing to add. Amendment to EIA section 5.1.7 and Annex 7
178
based solely on a qualitative assessment. A quantitative modeling is lacking on how this mixing will take place, and information on existing background levels is missing as well. The conclusion that treatment is not necessary can have far-reaching and long-lasting consequences, if this turns out to be wrong. It is therefore KANUKOKAs opinion that this assessment should be based on a more solid basis, and be founded on the precautionary principle.
24.29 At the public meeting on the 8. October in Katuaq one person referred to a report which according to this person shows that one of the reagents, xanthate, which is to be used for the removal of sulfur from the ore, is more harmful to the environment than indicated in London Mining EIA report. The report was prepared by the Australian National industrial Chemicals Notification and Assessment Scheme, an adviser to the Australian authorities concerning Chemical Safety. Orbicon said they were not aware of that report /study. In order to assess the value of the mentioned report, as well as to meet the criticism and the public concern, the presented report should be assessed by an independent expert, so it will be decided on a professional basis whether the report's findings should be included in the environmental assessment of iron mining project. And on this basis the needed
The report is in fact known to Orbicon and the report is also included in the reference list (EIA Annex 7 – Water Management Assessment). This fact became evident after the meeting when the full title and report was identified (NICNAS: National Industrial Chemicals Notification and Assessment Scheme (Australia). 2000. Sodium Ethyl Xanthate Priority Existing Chemical Secondary Notification Assessment Report No. 5S. Full Public Report). Without referring to the title in the meeting when presenting the statement, it was difficult to make an instant answer to this statement during the debate. Moreover, the report referred to is “A second notification” which assesses liquid xanthate. This product is not used in the Isua project. This liquid reagent has other characteristics compared to solid xanthate planned to be use in the project when sulfur reductions are required. The use of solid xanthate is explained in the EIA (Section 5.3.3 in the EIA - Annex 7).
BMP: The authorities including the National Centre for Environment and Energy (DCE) have been looking into the comments from the public review meetings and has also been in dialogue with the company regarding these issues. Requirements related to Chemical Safety will be set in the government approvals in order to meet international best practice. The final EIA reports are assessed by independent experts as DCE and GN (both of which are considered independent). DCE/GN: Reference to answer 7.1.
None
179
revisions of the conclusions and similar requirements which have to be made in the mining license to London Mining.
Characteristics of solid xanthate are detailed in the NICNAS report from 1995: Sodium Ethyl Xanthate Priority Existing Chemical No. 5. This report is also listed in the EIA references and has been part of data compilation presented in the working document: Note on literature data of reagents. Working Document, Feb.2012, Orbicon (also listed in the references). Toxicity assessments are complicated and require distinguishing between lethal concentrations (LC), effect concentrations (EC) and predicted no effect concentrations (PNEC) since these results differ greatly. These fundamental aspects have obviously not been accounted for in the statement from the participant in the meeting when he was made citations from the report. The statement presented at the meeting is therefore not justified and there are no discrepancies between the Australian report data and the data presented in the EIA. Details on chemical composition from the potential suppliers will be presented to the DCE/ GNIR as part of the approval procedure.
24.30 p.204: It appears that SGS Lakefield and AMEC (Canada) has conducted environmental analyzes on four samples from material similar to tailings from Isua. What are the reasons that the analysis is not performed on material taken from Isua? Which uncertainty does this imply in relation to the results obtained? And is a spot test of
All samples have the origin from the Isua iron ore formation. The term “similar” in the comment is not right. All material tested were obtained directly from the Isua deposit by drilling. All testing were done using actual real material from the Isua deposit. Furthermore, the 4 tailings samples tested are all the samples produced from 1 year of metallurgical
DCE/GN: Nothing to add. The explanation of composite samples will be included in section 7.1.11.
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four samples sufficient to give a true and fair view?
test work program at SGS Lakesfield. The samples are not spot test. The four samples represent composite samples of low grade ore; medium grade ore (two independent samples) and of high grade ore. The composite samples are used to increase the representatively of the tailings and considered to give a true and fair assessment of the characteristics.
24.31 EIA report generally The tables of the assessment of individual factors effects are not consistently filled out. An example is provided in Section 6.2.7. and 7.2.9., which both deal with the introduction of non-native species with ballast water for the construction and operational phases respectively. The risk for both activities is likely to be similar in the two phases, but the assessment of significance is different. At the same time it is a question whether complying with international rules is a "mitigation measures", or simply a basic condition.
We disagree with the KANUKOKA conclusion that introduction of non-native species are identical in the construction phase (cf. section 6.2.7) and the operational phase (section 7.2.9) and consequently the impact matrix should be identical.
In the EIA (section 6.2.7 and 7.2.9) it is explained that the construction phase will imply most ships will call the port loaded with goods to the site and thus not be in ballast mode. Contrary, in the operational phase most ships calling will be large bulk carriers in ballast mode.
Therefore the release of ballast water will differ in quantity and frequency and consequently the impact significance is phrased Low in the construction phase and Medium in the operational phase (before mitigating measures of complying with treatment of ballast water).
DCE/GN: Nothing to add. None
24.32 The descriptions of mitigation measures are several places too vague, and it is unclear what in the report is defined as mitigation action. Examples:
The EIA report contains the views of the independent consultant Orbicon. If London Mining is granted the permission to start the construction works, the Greenland Self Government and its administration (BMP) will specify the conditions for
DCE/GN: Nothing to add. None
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It is said on p.158: as "mitigation measures" for disruption by passage of vessels: "keep low speed in the fiord" - the report should be based on scientific studies and / or experience indicate a recommended speed limit, distance or noise limit. P.194: The only proposals for mitigation measures against the effect of dust and air pollution, is compliance with the latest emission standards. There are no concrete proposals for how this can be achieved for each of the possible sources of the process.
the permission. Such conditions will typically include the mitigation measures proposed by the EIA consultant. These mitigations will then be very specific. For example could a mitigation proposed in the EIA such as “keep low speed in the fjord” be converted to “ships to the Isua port must observe a X knot speed limit in the fjord”. The same will apply to for example air emissions and dust. In this case it is very likely that the BMP will require compliance with either Danish or EU emission standards which were the limits considered in the EIA.
24.33 Legends, north arrow and scale are missing on many of the maps. Many of the characters are unclear and of a poor resolution, so they are difficult to read when the document is printed, and the figure explanations are several places not adequate in order to understand the characters.
We are uncomprehendingly on this comment. Legends are generally included on sketches and maps or alternatively explained in the text. All maps and sketches are consequently oriented to the north. Important sketches and maps have a scale attached.
It is correct that sketches can appear blurred when printed. The document files are very large due to the number of illustrations. When the documents are published on the web site and shall be manageable for downloading it unfortunately necessitates a downscaling in resolution having the consequence of reduced printing quality. The documents can be provided in high resolution if required.
- None
24.34 In several places the text is vague and there is signs of insufficient quality control, for example is the text on page 116 regarding ice almost impossible to understandable.
Examples: On p.113 is mentioned "boulders" scattered in the landscape (boulders are shaped
Originally, the EIA has been drafted in English and subsequently translated into Greenlandic and Danish under great time pressure. Despite quality control typist errors or misunderstandings translating technical terms can be observed. They will to the extent possible be eradicated in the final version to be prepared after the hearing period.
DCE/GN: Nothing to add. Typist errors to be corrected
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blocks, and it's probably not what is meant?), P.118: "moraine" is a landscape form, the material is called "till" in all scientific literature. P.218: under "Mitigation Measures" is stated that "in the event that discharges do not meet the agreed levels actions must be taken immediately to ratify this" - what does it mean? And when you have "ratified", what then?
Comments to pages: p. 113. The English word ’boulders’ is translated to the Danish word ‘kampesten’. This is a precise translation. We disagree with the perception of KANUKOKA. p. 118. The English word ‘till’ is translated to the Danish word ‘moræne’ which is the correct expression (cf Den Store Danske Encyklopædi’ - Gyldendal).
24.35 The overview of the monitoring program is very uneven in quality. Some points are satisfactory described, while others are so incorrect defined that it is not possible to make an objective assessment. It is not enough to write that "A series of monitoring programs will be part of ..." without describing what these monitoring programs should contain.
The monitoring program to be implemented under the Isua project will be prepared and agreed upon in a co-operation with LM, BMP and DCE. The proposed monitoring program in the EIA is indicative for the approach.
DCE/GN: Nothing to add. None
24.36 The EIA report is unfortunately in too many places characterized as being prepared for the mining company, and there are passages in the report that seems colored by its wish for a particular design of the project and not a real independent description of the expected environmental effects based on a professional assessment. Formulation such as the headline of section 4.8: "Built eco-design" - gives the impression of bias opinion and should not belong in a report which will form the basis for a reliable assessment of environmental impacts of the project.
Orbicon A/S that has been contracted by London Mining to prepare the EIA report as independent consultant. The EIA report has been prepared in accordance with the BMP EIA guidelines and in close dialog with London Mining. In the cause of the process consultations have been held with BMP and their consultant to clarify approaches. However, the assessments of the various impacts of the project and conclusions are Orbicon’s own.
DCE/GN assesses overall, that the EIA report gives a comprehensive picture of the project's environmental impacts.
None
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24.37 The section on effects on the local fauna provides generally the impression of being well written and expected effects are sufficiently described, but KANUKOKA think overall that there should be expected a higher quality of an environmental assessment for such a large project.
The EIA has been prepared in accordance with guidelines issued by the Greenlandic authorities (BMP). Before the EIA was uploaded for public hearing the BMP scanned all the documents to determine if the quality of the EIA is sufficient to be used in an approval procedure.
DCE/GN assesses overall, that the EIA report gives a comprehensive picture of the project's environmental impacts.
None
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24 A. KANOKOKA (Bilag A – Qaasuitsup Kommunia)
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA
24. A 1
Kanukoka Mining Group Re.: Contributions to the hearing response in connection with the London Mining project – Isukasia From Ilulissat, Qaasuitsup Kommunea
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-
-
From Qaasuitsutp Municipality we must point out that we find it unfortunate that London Mining has not hold public information public meeting about Isukasia project. It is our experience that in general there is very strong support and adherence to that London Mining must complete their project in Isukasia. But the citizens lack information on job opportunities in connection with the project and lacking information about the courses or qualification efforts that will be associated with the project. Qaasuitsup kommunia is affected by large unskilled unemployment and there is a great need for upgrading the labor force from the known jobs for new job opportunities that will come in connection with Isukasia project.
The municipalities that have been engaged in the SIA process and where information meetings have taken place has been organized in agreement with BMP. However, with respect to job opportunities for the people of Qaasuitsutp Municipality, London Mining will arrange information meetings later on in the Municipality once the project is moved in the next phase.
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The municipality's economy has been hit hard because of declining activities within the fishing industry and jam in the construction industry. Therefore, are new large-scale projects that can help to create new jobs - also with labor from Qaasuitsup Municipality - more than welcome. Therefore, our unique opinion is that London Mining's Isukasia project should be initiated without further delay. The sooner the better. We are ready for concrete actions that could help both to reduce unemployment and initiate training activities that makes that the available will be upgraded and in all can look forward to a job. Kanukoka's draft to the hearing response can we also connect us to.
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24 B. KANOKOKA (Bilag B – Qeqqata Kommunia)
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA
24 B 1
Re. Hearing of the Isua projekt It is a very thorough response prepared by KANUKOKA. The only comment from Qeqqata Kommunias is addressing the aspect, that utilization of hydropower should not be completely neglected as a possible energy source, although the EIA is stating that hydropower construction will incur additional capital costs of approx. 900 million. USD. The potential of Imarssup Isua is reserved for the Alcoa project, but there is also considerable potential in the large lake Tasersuaq. Exploitation of hydropower will increase the project's environmental profile considerably, and it seems obvious that London Mining should enter into negotiations with Alcoa on takeover of the Tasersuaq power plant when the mine is closing down. This will allow Alcoa to increase the production at the smelter for a relatively modest investment. The Alcoa project has a much longer time horizon than Isua project.
London Mining has made a general response to questions related to utilizing hydropower potential as part of the project. Please see response for question no. 5.1.
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25. Birger Poppel
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA
25.1
As stated in the coalitionagreement for the Naalakkersuisut regarding the values of the coalition: “ A solidary, cooperative and strong selvgovernment should be developed that relies on open, democratic dialog. This imply that the people have joint influence and responsibility for the development of the society based on peoples equal worth and equal dignity” (the bold markings are Birger Poppels).
The four public meetings BMP has held since
the end of August on the ISUA project, do
not live up to the value set for formulations
of 'an open democratic dialogue' and 'public
participation and responsibility for social
development'. It is due, inter alia, to
following reasons:
Comment for the Government of Greenland.
BMP: Noted.
None
25.2 Only part of Greenland's population have been included in the information on ISUA project: ' Working together, we can and will make history in and for Greenland!' The quote is from London Mining’s Power Point
Comment for the Government of Greenland.
BMP: There is a continuously evaluation of the hearing process in order to have this improved.
None
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presentation that summarizes LM's assessments. This quote was pronounced several times during the public meetings by LM's director Xiaogang Hu and was supplemented with comments stating like the ISUA-mining project as Greenland's largest industrial project ever. It will also mean that if LM gets the exploitation license - the construction of iron mine and the subsequent operation will have far-reaching consequences for the whole Greenland. Therefore, it is necessary that the entire population of Greenland - and not only the residents of Nuuk and Kapisillit – will be involved in the discussion about ISUA-mining project. It has not been the case!
25.3 For a short time for a real debate on an informed basis:
The time that been available for going through the comprehensive documents (even without attachments) and for non-professionals a difficult task, has effectively been limited to approx. two months when the SIA and EIA only have been available in this period. This means that a qualified preparation and participation in a public debate has been impossible for anyone who has not been able to put everything else aside and concentrate on the report read. Since it is crucial to be able to handle a project like London Mining’s iron-project on a fully informed basis and in a context, it is in this less interesting context that over a
Comment for the Government of Greenland.
BMP: There is a continuously evaluation of the hearing process in order to have this improved. Comment referring to the consultation period is noted.
None
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period of several years that workshops and information sessions have been organized. There were nine weeks from the publication of the reports; an applicant is required to prepare for the consultation deadline, which is crucial.
25.4 The organization of public meetings in Nuuk has not adhered to democratic criteria or standards of professional meeting management: The public process, as it has been arranged, with four public meetings effectively excluded discussions, and the answers to some of the questions raised at the first meeting first was answered at a subsequent meeting (for the third meeting only in writing form) without the possibility for detailed questions, have been very far from a democratic inclusive process. Despite Naalakkersuisoq for raw materials and commercial issues and BMP claims to the contrary, the process is indeed far from the 'Canadian model', which occasionally has been referred to during the public meetings. When the Canadian process has been highlighted due to, among other things, that it allows local communities to assign experts to assess the material (environmental assessments and evaluations of social impact), companies present and that the process itself extends over a considerably longer period.
Comment for the Government of Greenland.
BMP: There is a continuously evaluation of the hearing process in order to have this improved.
None
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25.5 Solid citizen criticism:
One of the most consistent feature of all
four public meetings have been widespread
dissatisfaction and a massive criticism of
meeting content and form and the process
itself, which have had the name of 'public
consultation' but, at best, have been 'public
information'.
From the first to the last public meeting,
there was a growing (albeit not impressive)
participation. The experience of this process
is that it takes time to draw sufficient
attention to a very important project, and
the experience may lead to longer course –
and hence more time.
At the end of the consultation period, the
4th public meeting on 8 October which was
recorded was still not put on the hearing
portal. Nor answers / comments on the 52
questions and comments contained in the
minutes of the third public meeting on 24
September were seen published.
Comment for the Government of Greenland.
BMP: There is a continuously evaluation of the hearing process in order to have this improved.
None
25.6 Sustainability / environmental impact
In the coalition agreement the principle of
sustainability is stressed in the following
Comment for the Government of Greenland.
BMP: Noted.
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191
quotes:
"The original communities must be
strengthened and contribute to a society
that is based on the Greenlandic culture, and
how change is created taking into account
the collective sustainable management and
exploitation of living and non-living
resources." And "A self-governing Greenland
is a country where the exploitation of
resources is based on the principles of
equality, community and sustainability, and
where the self-sufficiency of food is also
pursued." (My highlights)
Greenland's international responsibility is
pointed in the following passages:
"A self-governing Greenland is also a country
that takes its share of global responsibility,
and one that cares about and collaborate
with other indigenous groups, and the rest
of the world."
"Therefore, a self-governing Greenland and
its people shall meet and reach their
international obligations and responsibilities
that apply to them." (My highlights)
London Mining’s summary conclusion of the
investigations of ISUA iron ore project's
192
environmental impact is:
" ISUA is an environmentally friendly mining
project with low volumes of waste materials,
clean operation and simple closure
requirements". (From London Mining Power
Point presentation) and it is emphasized that
”No significant environmental issues were
identified ".
The two quotes are remarkable, as one of
the most significant consequences of the
project is a near doubling of Greenland's
total CO2 emissions. This is primarily due to
repeated questions at the public meetings
that this fact is revealed and has to occupy a
central place in public debates. Such an
important relationship dimmed by London
Mining can also contribute to skepticism
about whether other key issues have been
underestimated.
The cause of CO2 emissions from the project
is that LM has chosen to use diesel
generators for production. This means that
more than 200 million liters of diesel
(London Mining data) will annually sail to
Nuuk and through Nuup Kangerlua in giant
tankers. In addition, the risks that the actual
transport, which the transport could lead to,
will the transport lead to an additional
193
amount of CO2 emissions from tankers, and
this release is not included in the more than
80%, Greenland's CO2 emissions are
expected to increase by. The extent of this
spill is not available, but should be
documented.
Compared to Naalakkersuisut recognition of
'sustainable management' and 'international
obligations', it does not matter whether
Greenland is exempted from a follow up to
the Kyoto Protocol, and CO2 emissions from
tankers conferred other countries'
emissions.
25.7 The use of hydroelectric power, (which seems to be available in sufficient quantities) must be not only a legitimate expectation but also an indispensable requirement, which should take precedence over investor repayment. China Development Bank (CDB), the London Mining CEO, Dr. Hu who is listed as probable investor (interview in Nuuk Local TV, October 1, 2012), has sustainability as a key success factor for its investments. Any iron mine in the bottom of Nuup Kangerlua based on hydropower could contribute to CDB's environmental profile.
Greenland has during many years been 'branded' on a clean environment and sustainable use of energy. Thus, Royal Greenland marketed its products on the
Refer to response given in 5.1 regarding hydropower.
BMP: The Government of Greenland is focused on supporting Hydro Power if this is possible in a financial and a technical way. A decision related to the use of Hydro Power also has to be realistic, and therefore it is a must that all these considerations are taking into account when these decisions are taken.
None
194
basis of a clean aquatic environment. The implications of iron mining project in different shapes should be carefully considered because they can affect Greenland's international reputation. Based on Naalakkersuisut basic positions (see quotes from the coalition agreement), it is likely that any decision to grant permission for London Mining for the construction and production requires the use of hydropower.
25.8 Greenland's economic benefits
What is certain and known about the consequences of implementing a large-scale project such as ISUA-mining project is that there will be impacts on the natural environment and a wide range of risks. To make London Mining iron mining project interesting / worth to take on, a financial return for Greenland needs to be guaranteed for the economic benefits for Greenland by adding nature and the environmental risk to the project. Since Greenland is not operating with 'royalty', the direct revenue generated from mining activities, which the London Mining has sought its license of exploitation, are: • income taxes • corporate taxes from local businesses • Corporation of London Mining Income taxes will (at a given income tax rate) depend on the total payroll, distribution of local and outside labor and
No response required
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None
195
wage levels of the various groups and the effectiveness of the PA tax collection.
25.9 Tax Income
Payroll cost will depend, inter alia, on the requirements for minimum wages for foreign labor. The lower salaries accepted in the bill for the large-scale projects, the lower the income tax. There are several reasons (including international conventions, rejection of social dumping and Greenlandic companies' competitive situation) to focus on the requirements from the Self-government for minimum wages, and one is that tax income as the only income the Self-Government is sure to get from construction of the project startup. The Self-Government’s considerations in this area has been absent from the debates. In the operational phase, it is expected that a greater proportion of the workforce will be local. It will depend on the qualifications of the Greenland applicants, how many people are employed, but tax revenue would also during operation depend on the wage levels of the various employee groups. The current bill on the large-scale project, only covers specific conditions in the construction phase. For various reasons - see above - but also for income tax payments during the operational phase, it will be important to confirm that Naalakkersuisut
Comment for the Government of Greenland.
BMP: The bill on large-scale projects
which opens for foreign expertise,
labour and lower wages during the
construction period, is meant to
facilitate project with a construction
budget over 5 billion Danish kr which
cannot be implemented by the current
Greenlandic workforce. Such project
will generate tax revenues from person
tax during the construction and
operation phases.
Lower wages will generate lower tax income but lower wages also increases the profit and thereby the revenue from corporation tax. It is not Naalakkersuisut’s intention that the favourable tax condition will include the operation phase.
None
196
will not give more favorable conditions during the operational phase. The question is relevant because of the experience – e.g. from Sierra Leone, where London Mining has apparently negotiated extraordinarily favorable terms by a direct agreement with the local government. Commitment to strengthen (and not relax) the conditions will provide a better basis to match revenue expectations for. (Http://www.christianaid.org.uk/Images/sierra-leone-mining-briefing.pdf)
25.10 Corporate taxes from local businesses
The size of the local corporation will depend on the extent to which local firms have the contracts, and their scope will again both in operating and construction phases depend on the extent to which firms are competitive. Here, an important parameter is about wages - the more favorable conditions for foreign businesses, the worse the Greenlandic economy is lodged. Also for this reason a clear indication is important from Naalakkersuisut on any future reductions / exemptions in relation to minimum wages, act on trade and industry.
Comment for the Government of Greenland.
BMP: The special conditions regarding wages which are described in the bill on large-scale projects covers only the constructions phase not the operation phase. The operation phase must take place under the normal conditions as described in the Mineral Act § 18 stk.1 and 2 regarding inclusion of Greenlandic labour and businesses.
However, it should be noted that the project cannot be implemented in accordance with the bill on large-scale projects if not an IBA agreement has been signed by Naalakkersuisut, Kommuneqarfik sermersooq and London Mining. Greenlandic workers and companies will not compete with foreign labour
None
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and businesses because the IBA agreement states that if qualified workers are available and companies are available which are competitive commercially and technically, they will be offered the jobs/deals first. Only after this procedure has followed can the remaining jobs/deals be offered to foreign labour/companies.
25.11 Corporate taxes from London Mining and other foreign companies
London Mining will begin to pay tax when capital expenditures and expected closure costs are written off. Is there any estimate as to when the first income tax payments from London Mining can be expected? Far larger and more experienced countries / states with strong resources and specialized tax administrations have problems securing corporate tax paid, where the multinational companies have revenues. It is not specify - apart from a few comments in the EIA on hiring more in tax administration - how Greenland is expected to manage the task of collecting tax revenue estimated at 28.5 billion DDK over a 15-year period.
London Mining is estimated to start paying dividend withholding tax immediately after one year of operation; corporate taxes will start to be collected when the company cellects profits. The personal income taxes will start as soon as the construction starts. Greenland has an established legal system, including tax laws and London Mining will follow the laws.
BMP: A number of variables influence the tax revenue from the project. Naalakkersuisut together with external consultants are currently assessing the economical revenues including the tax revenue.
Naalakkersuisut is aware that the staff
and expertise of the administration,
including the tax administration, but be
prepared for the tasks in the coming
years. Naalakkersuisut is prepared to
support the administration with
external specialists is needed.
None
25.12 Other factors that may affect the Self-Government’s income: Greenland gained experience from the gold
BMP: The Greenland Selfgovernment has no exact knowledge about the risk
198
mine at Nalunaq in South Greenland and olivine at Atammik in Fiskefjorden respectively, and their minelife is actually dependent on the world market, and Greenland has no influence on this. How does these experiences effect the Self-Government assessment of the London Mining project's with regard to long-term economic effects - including the risk / likelihood of a closure within a 15 year period?
Comment is a matter for the Government of
Greenland.
of the project closing ahead of time because of external factures. However, it has minimized the effects and expenses by requiring that a doposit must be paied to the government to cover the expenditures of closing the minen.
None
25.13 There are many parameters that affect earnings (and thus the Self-Government derivative income) in addition to the world market:
• Operation period length. Feasibility study for the iron mine is calculated from an expected operational life of 15 years. It is likely that the overall incidence may include a duty cycle for a total of 30 years, and even longer. It will only be finally resolved in the course of five years (information from Dr. Hu). • Transport distance from the mine to the port of discharge decreases. It is anticipated that approximately 70% are to be sold on the Chinese market. In the context of climate change, there are expectations that a northern sea route will be available to an ever greater extent. This will mean radically changing cost conditions (confirmed by Dr. Hu).
The BFS can only be carried out for the confirmed ore resource. The current available resource can only supply 10 years of mine life with 15 Mtpa production rate. It is expected that with an additional of 10000 m of drilling, the confirmed resource will eb sufficient for 15 years of mine life.
North sea routes can be good wishes but can not be
used for a BFS as it is not proven.
Please refer to question No 5.
199
• The energy form (s). The use of hydropower resulting in increased construction costs, but radically less operating expenses, which obviously felt more forcefully, the longer the operation period will be. These factors must be considered in relation to the expected development of the world market. After information from London Mining are the Bankable feasibility study not developed for more than 15 years. In spite of this, there may be reasons to consider also a longer-term perspective than the 15 years - including for the demands and expectations for energy use.
This is not allowed for a BFS, as discussed
previsouly.
25.14 The EIA and SIA assessed respectively consequences for the environment, populations of fish and animals and derived consequences for the fishing of fishing for commercial and recreational hunters (including traditional activities). At worst, the effects are assessed to have limited negative impacts despite the fact that there is such a marked increase in traffic in Nuup Kangerlua (tankers, supply vessels and ships carrying iron ore and passengers).
Viewpoint acknowledged – no response required. DCE/GN: Nothing to add.
None
200
25.15 Synergy with tourism and leisure services is also assessed as being positive to some extent. It seems likely that a major industrial activity in the fjord will make tourism more attractive and popular. It is not what has emerged from LM's presentations (both BMP and LM's own briefing), where the mine's employees must not move outside the mining area, and during transport from Nuuk to mine and back they will be accompanied by security personnel from the mine.
The SIA has assessed the long term potential positive impact on the tourism during the operations. The transportation and management methods referenced in the question refer to the construction periods which is a short term issue and is not significant.
None
25.16 To manage - as supervisory authority - the series of activities and issues that are current, if the Self-Government authorizes the construction and operation of an iron mine. It requires the establishment / construction / expansion of expertise in a wide range of areas such as.: immigration / foreigners (currently state responsibility); customs and tax environment; Nature Conservancy; work (currently state responsibility); ship inspection (currently state responsibility). This means that there will be held a variety of costs (especially if the Self-Government intends to take such migration / immigration from the state) before there will be income of a significant degree within the Treasury. What consideration has the Self-Government done to prevent this?
Comment is a matter for the Government of Greenland.
BMP: There is a continuously focus on the requirements imposed on the government administration related to the development of mineral projects in Greenland. This is also why the hearing process is important, as the different departments and institutions in this process is given the opportunity to evaluate whether further assistance is needed in the short and in the long run. To mention one example; the Tax Authorities have already voiced this issue as the demand for control etc. in this area of administration is substantial.
None
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25.17 The debate emphasized that a prerequisite for a successful outcome of such a project as London Mining iron mine, is the use of local labor. A significant part of the latter will be trained to perform jobs in the mine. This raises a number of questions: o What are the forecasts and plans already available for the training of potential employees for mining sector? o What is mobility: how many want in the different circumstances to travel / move to work in the mine (results from 'the mobility study' did not indicated a very high readiness to move)? o If the opposite is proved that mobility is large, the emigration of educated people from villages and small towns outside of Nuuk mean an migration of the most qualified people (which an important resource), which may be important for these places cohesion and survival.
Comment is a matter for the Government of
Greenland.
BMP: In the education system today there are already a number education actions related to the exploitation sector. Among others the Mining School in Sisimiut can be mentioned. Besides these established actions, themes as education, local workforce, apprentships and similar workforce related issues will be a part of the IBA negoations. The Impact Benefit Agreement (IBA) is a concrete action plan focusing on these issues and is therefore considered an important education related document.
Mobility and related issues will be monitored throughout the project in order to give a foundation for eventually future corrections. Detailed monitoring plans have to be prepared by the company (London Mining).
None
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26. Avataq
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA
26.1 Energy and air emissions
Avataq notes that London Mining Plc (LM) is
planning to use diesel-powered generators to
meet the energy needs for both mining and
port facilities (viz. 130 MW and 25 MW). In
view of the large hydropower potential in the
area, Avataq considers this deeply
problematic and contrary to all good
intentions from official sources emphasizing
the use of non-fossil energy production.
As justification LM indicates that the
hydropower potential cannot meet the total
needs of 155 MW. This is difficult to take
seriously when pre-investigations made for
decades - and even in the former iron mining
project design - is indicating the presence of a
potential of up to 200 MW.
Furthermore, LM justifies the use of diesel powered electricity production with the construction of a hydroelectric power plant will take up to seven years. This is also contrary to other plans utilizing hydropower
Please confer response to questions detailed in 5.1
and 5.2 as well as answers to questions raised at the
3rd public hearing meeting (no. 7-9, 15, 31-34).
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None
203
potential. These plans operate with a time horizon of five years at the most.
26.2
Avataq considers it deeply problematic that this one project with this kind of energy production will increase Greenland CO2 emissions by 89%. In addition, the emission of the so-called black carbon i.e. soot particles (PM2.5), which is commonly realized having a strong negative effect, both when it comes to warming of the atmosphere, in connection with the deposition on snow and ice, which will include increase the melt of the ice cap. In addition, it is known to be a connection between PM2.5 and increased mortality due to respiratory and heart diseases and some types of cancers deceases.
The Avataq statement on CO2 emission increase is noticed. However, the apparently dramatic increase of 89 % shall be seen in the context with the fact that Greenland has a very low CO2 emission (i.e. total quantity of CO2) because of the very low number of inhabitants and low industrial activities. All new major industrial development in Greenland will relatively add to increasing CO2 emission in Greenland – also in case hydropower is utilized. See also answer to 5.1, 12.2, 13.4, 24.26 regarding CO2. Black carbon (BC) is a major component of soot emitted by incomplete combustion of fuel. BC influences cloud formation and reduces the reflectivity (albedo) of snow and ice when it is deposited. BC also contributes to the adverse impacts on human health of PM2.5. Most BC in the Arctic comes from emissions outside the Arctic. The air emission from the modern and highly efficient diesel power plants specified for the Isua project and running on low sulphur content diesel oil will fulfill stringent international criteria to particulate emissions. The EU enacted PM2.5 ambient air quality criteria specified in a EU directive (Limit values in ambient
-
None
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air for protection of human health and the environment) and enacted in Denmark (cf. BEK nr. 851 of 30/06/2010) are fulfilled in the entire port area and at the mine area outside the open pit. Since Black Carbon is an integrate part of particulate matter, the health effects associated with Black carbon are taken into account in the EU limit values for PM10 and PM2.5 for the protection of human health.
26.3 Another problematic issue related to emissions of soot (PM2.5) is the use of heavy fuel oil on ships to transport iron concentrate through Nuup Kangerlua. To remedy this serious problem the IMO is preparing the so-called Polar Code including a significant reduction in the emission of soot using the heavy fuel oil.
Recent studies indicate that there is no significant difference in soot or black carbon emission between heavy and light fuel oil.
The perspective of a Polar Code and the
international initiatives to regulate heavy fuel oil in
Arctic waters has been addressed in the EIA (Section
7.1.8).
The viewpoint of Avataq has been noted for future
detailed planning and work and is a matter for the
Government of Greenland.
DCE / GN recommend that requirements are set which comply with the IMO recommendations. Refers to the previous section 11.11.
None
26.4 Avataq would therefore recommend that LM continues to work towards finding a solution taking advantage of the area's hydropower potential instead of using polluting diesel generators. The project should not be implemented without utilizing hydropower. Additionally, we recommend that the project takes advantage of vessel capacity not using heavy fuel oil in order to avoid serious inconvenience from this type of fuel and
London Mining has noticed the position of Avataq.
BMP: Requirements related to heavy contra light fuel will be set in the government approvals.
None
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therefore strives to follow the recommendations considered to be the Polar Code.
26.5 Ballast Water Avataq notes that the EIA addresses the problem of introducing invasive species through the discharge of ballast water. In Navigational Safety Investigation it is stated that the Regulation D-2 of the International Convention for the Control and Management of Ships' Ballast Water and Sediments (BWM) will be pursued.
It is desirable, however, that it is made clear
who is responsible for the provisions of the
BWM is followed. In Annex 7_Water it is
indicated that "It is assumed that
responsibility for ships following the
convention will rest with the shipping
companies. How can it be assured that the
regulations are complied with?
Additionally, there is a lack of arguments why
Regulation D-2 is being satisfactory compared
to Regulation D-3, D-4 and D-5 as well as the
potential emissions to be expected in
connection with the discharge of chemically
treated ballast water.
The responsibility of proper ballast water management system is the owner of the ship (as stated in the EIA).
Inspection and control of the management system
including the Ballast Water Record Book and/or
sampling of the ballast water can be made by the
port State control officers according to BWM
convention Article 7.
The BWM convention has in its Annex D several
regulations numbered D-1, D-2, D-3, D-4 and D-5.
The Regulation D-2 is named “Ballast Water
Performance Standards”. These are the overarching
performance standards used in the convention and
to which the various methods shall comply with. This
is the rationale for making reference to this specific
regulation in the report.
The other regulations deal with other subjects e.g.
“Approval of Ballast Water Management Systems”
(D3); “Prototype Ballast Water Treatment
Technologies” (D4); and “Review of the Standards by
Organization” (D5).
There are no discrepancies between the various regulations. The D-2, D-3, D-4 and D-5 are
BMP: Requirements related to discharge and inspections will be set in the government approvals.
DCE/GN: To reduce the risk of transfer of invasive species in ballast water, DCE/GN reccomend that all ships that come to Greenland from international waters and ports must discharge/replace ballast water in a zone between 200 and 300 nautical miles from the coast of Greenland. In addition, the ballast water should be treated when IMO’s Ballast Water Convention is brought into force. DCE/GN refers to the document ”Environmental Requirements and Conditions” (draft DCE/GN February 2013).
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complementary to each other.
26.6 Tailings
Avataq has no qualifications to comment in
detail on the discharge which takes place
from tailings lake and sedimentation basin.
We note, however, that the emission from
Lake 750 will end up in llulialik and Nuup
Kangerlua because the lake - through
Tarsartuup Tasersua - has its final outflow,
and at that point hazardous chemicals will be
discharged into Qussuk.
We also take note of the discharge of various
metals to be estimated in many tonnes and it
gives the cause for great concern. We have
noticed that studies have not been carried
out to give any certain conclusion about the
impact of the so-called cocktail effect can
have in an eco-system.
This topic is not addressed in the EIA. The
cocktail effect i.e. the fact that different
chemical components in various combinations
may have a (strong) increased eco-toxicity, we
believe is a serious shortage in the report.
The effluent criteria will have the overall objective
that there will not be toxic effects in the aquatic
environment outside a dilution zone.
Control of the criteria compliance will continuously
be monitored by the company's internal control and
by authorities. In addition, the environmental
monitoring includes measuring toxic effects.
In general iron ore exploitation don’t generate
release of large amount of heavy metals to the
aquatic environment. Comprehensive geochemical
tests of the Isua iron (cf. the EIA-Annex 8) confirm
this conclusion.
The processing will not add significant amounts of
metals transported through the aquatic
environment to the fjord compared to the natural
transport of material (including a suite of metals)
transported in melt water from the glacier
influenced catchment area . Refer to answers in 7.1,
20.2, 20.3, 20.4, 20.8.
London Mining agreed with the recommendation
made by DCE, and London Mining is committed to
performing complementary eco-toxicity tests early
DCE/GN: Comment in the document
with proposals for requirements and
conditions.
It is expected that the final EIA report,
as recommended by DCE/GN, will
include the results of ecotoxicological
tests based on ore, tailings and waste
rock.
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in the construction phase, once the necessary
feasible conditions for these tests are fulfilled,
namely confirmation of the protocols with DCE/GN,
access to the site for the shipping of actual samples
of Lake 750 water for the tests, availability of more
tailings and concentrate materials from
metallurgical tests. This commitment is stated in the
EIA which was issued for Public Hearings.
26.7
In addition, the LM should also be aware of
the available hydropower plans, which will
cause - if they are realized - that the Tailings
pond (Lake 750) will have its outflow in
Ujarassuit Paava fjord.
What impact will the many tonnes of
emissions have on the eco-system of this
fjords? It seems that this subject are not
treated in the report, and this is also a
deficency.
The EIA is deliberately dealing with the Isua project
only. The Isua EIA has to make assessment of factual
plans and cumulative effects hereof. (see also
response no. 20.3 and 31.2)
However, having made this position clear, London
Mining and its environmental consultant (Orbicon)
have no indications for flagging environmental
concerns related to the effluent from the tailings
lake and a changed position of the outflow to
Ujarassuit Paava fjord if the Alcoa hydropower
project materializes.
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27. Råstofskolen i Sisimiut
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
27.1 Greenland workers, such as a machine operator, explosive officers and those who have attended common corer courses, and skilled within mining and construction work as well as trainees. What is the pay scale out? Apart from the four areas!
The salery for Greenlandic employees will be based on the Greenlandic agreements between SIK and GA (Greenlandic scale).
- None
27.2 Will one also be paid also in free time, because free time is quite long. How much is the salary for the workers?
The salary will be distributed such that the workers get regular pay cheques. The salary depends on the position, experience and qualification.
The salary will be based on the number of hours
worked on site.
- None
27.3 How long must rotation schedules be? In the SIA, it says 4 weeks in and 4 weeks out, and in another part it says 6 weeks in and 3 weeks out so which one will it be?
In section 6.1.2.2 of the SIA it is assumed that the majority of the workers will be working on a 6 weeks in and 3 weeks out rotation during the operations.
BMP: Rotation schedules can also be an issue discussed at the Impact Benefit Agreement negotiations between London Mining, Kommuneqarfik Sermersooq and the Greenland Government.
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27.4 Should one decide yourself on union? within the mining and contraction work. Even if you have a local or country based Association (SIK), one must have a value as in a international base model! And one must be
Comment is a matter for the Government of Greenland.
BMP: If you for example are employeed in a Greenlandic registered company working on the ISUA project in the construction and production phases you are entitled to choose labour union
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able to even create a union! according to your own wishes, as long as you follow the requirements in the labour unions. You are therefore also free to create your own labour union
Additional questions from Kristian Andersen (student)
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
27.5 Do you have experience from mining industry in Arctic?
The Director and the Deputy Director for London Mining Greenland have significant experiences from mining industry in the Arctic. Furthermore, the engineering team is led by the Canadian SNC Lavallin, a well-recognised mining engineering consultancy, with a long list of references in mining in the Arctic.
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27.6 Equipment: Construction equipemnt and pipeline? Do you have these already
No. The needed equipment will be included in the tendering procedure.
- None
27.7 Wil the monthly salery include salery for freetime periods?
The salary will be based on the number of hours worked on site.
The salary will be distributed such that the workers get regular pay cheques.
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27.8 Where is the salery level? The salary level will follow Greenlandic legislation.
- None
27.9 Is it possible to use non-polution energy source?
As far as to the use of hydropower, see answer to question number 5.1.
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27.10 Will the permafrost potentially be a probelm in the construction of the road? And where?
The permafrost is not expected to be a problem for the construction of the road.
- None
27.11 (Culturel and naturel values) 9 out of 10 are hunters in Greenland, where do you have this from? And the dogsledgse during winter in Nuuk ”Isukasia”?
In section 5.8 Cultural and Natural Values is stated that 9 out of 10 consider traditional activities important for their identify and wellbeing. This information is from the Survey of Living Conditions in the Artic (Poppel et al 2007).
There will be no dog sledges used in Nuuk. It is only
possible to have dogs in Sisimiut (the southernmost
area in West Greenland, where it is legal).
- None
27.12 Are there room for apentices and employees with ”spouses and children”
The camp will not be for spouses and children. - None
211
28. Jacob Mathiassen
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA
28.1
I am generally positive about the use of the iron ore - and to the aluminum project - but I think there are serious shortcomings in the project design.
In any case, the project should be carried out
on the basis of the principles of
sustainability. The current project design
with two diesel plants totaling 160 MW
implies that Greenland's current greenhouse
gas emissions will double, which is
unacceptable when a hydropower potential
is available in the area. Using diesel is not in
compliance with either BAT or BEP.
It is the responsibility of Naallakkersuisuts
that projects in Greenland are implemented
in the most appropriate way. It is not
Naalakkersuisut responsibility that the
company maximizes its profits in the
shortest time possible. As the project must
comply with environmental regulations etc.,
Regarding that part of the comment about CO2 emission by Isua project, answers are given in 5.1, 12.2, 24.26 and 26.2.
BMP: The Government of Greenland is focused on supporting Hydro Power if this is possible in a financial and a technical way. A decision related to the use of Hydro Power also has to be realistic, and therefore it is a must that all these considerations are taking into account when these decisions are taken.
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Naalakkersuisut should ensure that the
project meets the Greenlandic legitimate
interest of reducing emissions of greenhouse
gases by e.g. using available hydropower
resources.
My main conclusion is therefore that London
Mining should not be given the exploitation
license until there is a satisfactory solution to
the energy supply issue. This should include
the power supply to the mine, but ideally
also the port by hydro-based electricity.
28.2 1. Ambiguity, omissions and possible sources of errors in the EIA and in the SIA when compared to BMP guidelines in November 2009, including non-compliance with the principles of BAT and BEP.
One of the main purposes of an EIA is
besides listing projects influences on the
environment, etc. to identify how these
impacts can be minimized or avoided
altogether. This is not done properly - if at all
– with regard to the hydropower potential
and economic comparisons between diesel
solution and a full or partial hydro-based
energy supply.
The principles of BAT (Best Available Techniques) and BEP (Best Environmental Practice) are mentioned in the Mineral Resources Act as well in the BMP EIA Guidelines. Detailed description of what is defined as BAT and BEP is not part of the act or guidelines. In the EU directives and thus the Danish legislation, the BAT principle has the following definition: ‘Available techniques’ means those developed on a scale which allows implementation in the relevant industrial sector, under economically and technically viable conditions, taking into consideration the costs and advantages, whether or not the techniques are used or produced inside the Member State in question, as long as they are reasonably accessible to the operator.
-
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In the EIA section. 05.4 on energy, it is said inter alia: "The 160 MW energy is 100% based on fossil fuel with diesel generators. Both hydropower as well as combinations of hydro and diesel power were also solutions taken in consideration. The possibilities of hydropower from the area have been studied for years. Based on the studies conducted (summarized in Annex 9), it is estimated that a plant based on lake Imarssuaq could provide hydropower approx. 120 MW. Hydropower based on lake Taserssuaq would deliver approx. 80 MW. In both cases diesel generators are needed to meet the full energy requirements. These alternatives seem attractive regarding reduced CO2 emissions, but studies have also shown that hydropower that would be involved in the ISUA project is not financially attractive. Water-power resources are also studied for other purposes, and will not likely be available in relation to the ISUA project. Overall, hydropower is not a feasible option due to the schedule for the ISUA project where operations start in 2015. Diesel generators can be established in the course of a year. "
In other words economically, technical and accessible aspects shall be considered before it can be concluded whether a solution is BAT or non-BAT. In the actual Isua iron ore project using diesel generated power supply, London Mining and its technical consultant (SNC Lavalin), has analyzed these aspects and concluded that the hydropower resources (the Imarssuaq scheme) is reserved for other purposes; that the constructing period for a hydropower plant is 7+ years conflicting with the marked situation; the construction is technical complex due to inaccessible terrain and harsh climate; and consequently the construction cost are high and uncertain; and will require a longer depreciation period than the actual proven iron resources allow. Thus the financing aspects are very difficult. The overall conclusion is that the hydropower solution is not technical and economic attractive. Also refer to answer given in 5.1 and 13.4. Therefore it cannot be concluded that the diesel solution is not BAT.
28.3 1.1 Incorrect inventory of hydropower potential:
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Hydropower potential based on Imarsuaq and surrounding water catchment area is not only 120 MW, but 175-200 MW, which is revealed by Alcoa studies which therefore implies that of the potential London Mining need for 160 MW can be met.
Nukiisiorfiit name it 06.g and on the basis of
measurements made in 1974-94, its
hydropower potential is estimated to be 154
MW. However, as observed for all
hydropower potentials which were
examined later, it is assessed this to be
higher today (+ 14-30%).
In addition to the other hydropower
potential mentioned in the EIA, Tasersuaq
(06.h) rated at 65 MW based on previous
measurements, while its potential is
considered to be 80 MW (i.e. 23% higher).
There is also a hydropower potential in
Southern Isortuup Isua (07.d) which was
rated at 125 MW based on previous
measurements in 1974-83.However, today it
is likely to be considerably higher.
It should also be borne in mind that Annex 9
only is "... initial evaluation study of
alternative hydropower plans ...". Therefore,
A number of similar questions and viewpoints on hydropower issues have also been raised as part of the 3rd public hearing meeting held on 24. September 2012. A detailed response has been included in replies to the 3rd meeting questions no. 7, 8, 9, 15, 31, 32, 33; and-34 and also summarized in the answer to the written comment no. 5.1 and 5.2. Please confer these replies.
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definitive conclusions should not draw for
the project on the basis of the studies,
London Mining has been carried out.
My conclusion:
It is not true that there is no hydropower
solutions to meet the full needs without
requiring additional diesel generators.
Moreover, there is nothing to prevent a
solution that combines hydro and diesel
power, if there is an indispensable need to
supplement available hydropower resources.
The need at the harbor - which over the last
year has increased from 15 to 35 MW,
without any explanation – could be covered
with diesel if another solution is not
possible.
Finally, there is the opportunity to resolve
any hydroelectric power deficit that the
project measured according to the available
hydropower resources. Feasibility studies at
10 Mtpa was, to my knowledge, also highly
profitable.
216
It is true that the potential is / has been
reserved for the aluminum project, but as
will be further described in Section 2, the
total hydropower potential of a total of
approximately 400 MW in the area, has to
be seen in conjunction with the aluminum
project and the objective of Greenland to
exploit the country's hydropower resources
to produce green power.
As late as in presenting the basis for the
decision proposal EM2012/113,
Naalakkersuisut stressed the rationale that,:
"Establishment of a number of large-scale
commercial projects - mining and industrial
projects based on the use of our
hydropower resources – will be considered
by Naalakkersuisut to be important
contributions to the development of our
country in the direction of becoming
financially self-sustaining." [My emphasis].
28.4 1.2 Economic comparison of diesel and hydropower solution and CO2 emissions:
The economic and other comparisons shown
The same viewpoints were raised at the 3rd public meeting and the replies can be seen in answers to
-
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in Table 4.9, page 93 appears to be partly
erroneous and incomplete not to use
stronger words. They even contradict clear
conclusions on the same page 93:
"The studies of hydropower as contained in
Annex 9 shows that the ISUA project with a
hydropower option is not economically
sustainable."
If we just look at the diesel solution (fossil)
compared to Imarssuaq (hydropower), then
the investment and operating costs are
calculated as follow (for 125 MW):
Mio U.S. $ Diesel Imarssuaq
(Hydropower) Difference
Investments (Capex) 221 677 +456
Operating expenses (OPEX) 299 42 -257
Additional investment for hydropower is 456
million U.S. $. The savings of hydropower in
operating costs is 257 million U.S. $. This
means that in less than two years of
operation, the entire additional investment
will be recouped.
no. 31 and 32 and for easy reference also quoted below: An engineering study has different accuracy levels. LM is not sure what engineering levels and development stages were the referred hydropower studies. For LM’s own reference, our engineering consultant SNC Lavalin has carried out its own study at a scoping level and concluded that the secure hydropower within the economical viability is as indicated in the submitted documents, that is 120 MW. LM does not have the right to use the water in the project area. The financial analyses have also shown that the capital investment has a very significant impact to the project economics. An accurate financial analysis has to take all factors into the evaluation, including the project capital cost, operational cost, production rate, estimated near term and long term product prices, financing conditions and freight arrangements etc. The simple calculation as shown in this comment cannot reflect the real project economic condition. Based on the financial model developed by SNC Lavalin, the increased capital expenses combined with the estimated delay for the production will make the project not financially attractive. This will make the project not feasible.
218
(There is negative cash flow during
construction, etc., but it does not affect the
overall picture).
If the total energy requirement is considered
to the effect of 160 MW, diesel consumption
will by 24syv operation and 85% load to 250
million liters per year. Import cost at the
current 5.85 kr / liter will be 1,463 million
DKK.
Regardless of how the equations are made
up, for a savings of over 1.4 billion DKK
interest and repaid even very large and
heavy investment hydropower plants over a
very short period of time.
The conclusion made by London Mining on
the lack of economic sustainability is
therefore wrong.
28.5
The figures for CO2 emissions are not
consistent with the statements Greenland
There are no contradictions between the EIA figures and the figures seen in Greenland Statistics. The figures for CO2 emissions from Greenland are based on Greenland Statistics Yearbook 2011
DCE/GN: Nothing to add.
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219
Statistics do. Based on the SG's numbers,
emissions of CO2 per tons of gas oil amount
to approx. 3.15 tons. London Mining
expected consumption of 250 million liters
of ~ 208,000 tons will imply an emission of
655,000 tons.
Greenland emissions from diesel in 2010
were 553,000 tons at a consumption of
about 176 million tons of gas oil.
having figures from 2002- 2009. The total import of liquid fuel as average of 2002-2009 was 251 million liter/year having an estimated CO2 emission of 0.63 million tons CO2 according to the Statistical Yearbook (i.e. average of 2.5 tons CO2 per m3 fuel). 82 % of the imported fuel is stated as ‘arctic gasoil’ and ‘motor gasoil’. The figures can be seen on the Greenland Statics web page http://www.stat.gl/dialog/main.asp?lang=da&version=2011&link=EN&subthemecode=t7&colcode=t The total estimated consumption of arctic diesel for the Isua project operational period is 210 million liter/year and not 250 million liter per year as stated in the viewpoint. Furthermore 78 % are used for power supply and 22 % for mobile equipment (cf. EIA section 4.7.1).
28.6 In Annex 9, section 4.4 is a financial analysis with the calculation of the project's internal rate of return, equity internal business and NPV after tax. These requirements are not specified, but it looks as if the value of the hydroelectric power plant after 15 years set to 0. Similar, it cannot be identified if the closure cost (clean-up cost) in the diesel scenario id included.
Based on a reviewed of the London Mining
figures, the project is anyway extraordinary
profitable, meaning that the payback period
of the investment is only 3.5 years,
increasing to 4.3 years if a construction of a
See response no. 28.3 and 28.4
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hydroelectric power station is built. The
increase from 3.5 to 4.3 years can probably
be explained by the negative cash flow
during the construction of the hydroelectric
power plant. As shown above, in the
following years, a saving in operating
expenses will excess 1.4 billion kroner, so
the equations will look completely different.
There can be only two reasons why London
Mining rejects the hydropower solution. One
may be that they are so busy to get started
that they do not want to spend time on
detailed studies and construction of
hydroelectric power station. The second is -
regrettable - that ISUA project cannot be
awarded the most obvious hydropower
potential, namely Imarssuaq. This issue will
be addressed in Section 2 below.
Refer to answer given in 5.1 and 13.4.
28.7 The preliminary conclusion regarding the choice of energy and the consequences for CO2 emissions, etc. can only be: London Mining takes wrong decisions in a preliminary, on the basis of incomplete and to some extent obviously wrong numbers.
The CO2 emission with an annual consumption of 210 million liter of diesel is estimated to 0.56 million tons CO2/year and is based on international acknowledged factors between CO2 and oil products used for energy supply. The CO2 emission from Greenland in the period 2002 – 2009 is based on data from Greenland Statistics. There is no reason for corrections of the CO2 emissions. Refer to answers given in 5.1, 12.2, 24.26, 26.2.
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The EIA and its assumptions should be
corrected and extended in terms of
economic calculations and assumptions.
The calculation of CO2 emissions should be
corrected and include emissions from other
activities, including shipping, if necessary,
emissions of greenhouse gases from
explosives, etc.
As appropriate, the results from adjusted
calculations should be included in the SIA
(e.g. the value of hydroelectric power for
other uses after termination of the mining
activities), expenses saved for purchase of
CO2 quota, etc.).
The CO2 emission from ships traffic to/from the mining project sailing through Godthåbsfjorden is estimated in the EIA section 7.1.8. The amount of CO2 from ships is modest compared to the overall emission from the project. Income from or value of hydropower plant beyond the project period used for other purposes not identified nor agreed upon is hypothetical and cannot be used in the BFS and is thus outside the project and the SIA. Trade with quotas of CO2 is a political issue. For the time being the future for CO2 trading is unresolved.
28.8 The EIA should also include a detailed description of the mining project discharge into lakes that may affect the same lake systems hydropower potential in relation to any changes in the distribution of runoff over the year, changes in water quality and the possible impact on the wear of turbines, etc. (The conveying water at approx. 8 million m3/year must be deducted from the
The question of cumulative effects utilizing water for transporting iron concentrate with other projects for utilizing hydropower has also been addressed in answer to hearing input 20.3. Please confer the response. However, the conclusion is correct since there will be no or only marginally consequences for the hydropower potential.
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potential of the lakes. However, this must be considered as marginal.
28.9 The SIA should include information about when the stipulated corporate taxes are expected to flow into the Treasury.
Same question has been answered as part of response 2.1. Please confer.
None
28.10 Tailings It appears that Lake 750, over 15 years, will be filled up with 232 million. m3 of tailings, i.e. approx. 15 million m3/year. After 15 years of operation, the remaining volume will be 32 million m3 or a maximum of two additional years of operation.
There are discussions about the possibility of
extending significantly the length of the
operating time (30 + years). Irrespectively,
that operation period is only planned for 15
years of operation, this crucial condition
should be assessed in the EIA in terms of
safe deposit and without pollution.
Conclusion
London Mining must explain how tailings are
expected to be deposited when Lake 750 is
filled.
The London Mining expectations are that the iron resource estimate can be upgraded to 15 years of mine life with a production of 15 Mtpa upon some additional exploration drilling. The assumption of 15 years mine life of 15 Mtpa has been the basis for the EIA. If the mine life is extended beyond the assumption for the approval the conditions shall be reassessed including assessment of the capacity of the tailings lake and a number of other conditions. Since there is no actual plans and no application for such a production this aspect is outside the scope of the EIA. Please also confer response to question 24.16. The DCE/GN comment about the requirement to prepare an EIA for an operating period beyond 15 years is noted.
DCE/GN: DCE/GN recommend that, for
any prolonging of the production
period, a preparation of an EIA be
required.
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28.11 Lake 792 It is mentioned in many different figures for the inlet and outlet of water from Lake 792. The question is really outside of what is central in this hearing input, but for information only some examples from Annex 7: 1) Page 64 mentioned that 3% of the outflow equivalent to 8.1 million m3 will be used to transport iron concentrate through the slurry pipeline to the port. The remaining 97%, which is also mentioned on page 63, must therefore be 262 million m3. 2) From Figure 2-4 on page 14 shows that the annual inflow is 91 million m3 and that 30.1 will be used to 'process and flush'. (Perhaps the figure of 91 is a typist error. If it says 191 the water balance in Figure 2-4 to fit reasonably).
3) In Table 4-2 is 'Annual discharge' (which I
assume means discharge) from the lake
listed as 133/138 million m3/year in
2010/2011.
4) In Table 5-1 on page 68 is 'existing outflow
from Lake 792 substracted process water'
set to 111 million m3. If the process water is
31, the total outlet in this calculation is the
141.
The water balance of Lake 792 and Lake 750 is important. The hydrology is however complicated which is evident when the water balance diagram in the EIA section 7.1.2 is observed. The diagram has been constructed with great care as part of the BFS utilizing all available hydrological data. The water flows are annual averages and considered to be the best estimates for long time series. London Mining has initiated hydrological measurements and figures from 2010 and 2011 are also seen in the EIA report. These figures are indeed not identical to longer time series which is clearly spelled out in the EIA report Annex 7 (section 4.3.1). The flow for 2010 and 2011 was higher due to higher melting rates compared to average melting rates based on long time series. Mentioning various figures for the outlet of Lake 792 are not indicative for ’errors’. The inflow in to Lake 792 will cease out in the winter period. The continuous abstraction of process water in winter month will consequently lower the water level in the lake. These consequences are also described in the EIA section 7.1.2.
DCE/GN: Nothing to add.
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It is surprising that a lake in 800 meters close to the ice at very low temperatures can be tributaries year round. With normal water consumption for 6-7 months, there will be a deficit in the Lake 792 of up to 15-17 million m3. Compared to the modest volume of the lake estimated to 41 million m3, there must be a significant risk that the mine cannot run at full speed all year.
28.12 2. The project's failure to meet the objectives of Naalakkersuisut coalition agreement, including the need to see hydropower resources for iron mining and aluminum project in a larger and longer-term context. London Mining during both informal conversations and later at the public meeting on October 8th stated that it would prefer to base the energy supply on hydroelectric power, but that it does not have the financial strength to build hydroelectric plant. If another company was to build hydroelectric plant with the ability to supply energy to iron mine, they will be more than happy to buy energy. (These statements are made in spite of the summary and incorrectly reasoned rejection of the EIA of a hydropower solution.)
London Mining is willing to purchase power from hydropower plants operated by third parties if these options exist. This has also been announced at the 3rd public hearing meeting – see answer no.9.
DCE/GN: See comment to question 5.1.
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225
London Mining has also expressed that it
was because of the intent to get started as
soon as possible with mining and it could
also imagine a temporary diesel solution
that replaces hydropower, once hydropower
plant (s) are built.
Conclusion
London Mining should be associated with its
application a clear expression of the
opportunities the company envisages a long-
term, environmentally friendly solution to
the energy, see the statements made
verbally by more or less official occasions.
28.13 Naalakkersuisut objectives on energy and the environment as expressed in the coalition agreement of June 2009 is clear and ambitious: "Climate area: ... By setting clear goals on climate change for the industry and for the rest of society we will ensure that Greenland also after 50 years is known as a beautiful country with a population putting actions behind its words when it comes to sustainable use of natural resources.
London Mining will indeed comply with conditions and requirements determined by the Greenland Government
DCE/GN: See comment to question 5.1.
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Energy
The energy sector must continue to focus on
development of environmentally friendly
energy sources, such as hydropower. A
Greenland, which primarily derives its
energy from green energy, is the bearing
vision…
Mining, heavy industry and oil
The prospect of rising global prices for
minerals and fossil fuels has renewed the
focus for ways to leverage our non-living
resources; the economic implications can be
very large. Therefore, it is important that
Naalakkersuisut mineral exploration policy is
closely coordinated with industrial policy,
labor market policy, environmental policy ...
We accept exploitation of non-living
resources as an important potential - not at
the expenses of the environment. When
self-government is a reality and Greenland
has taken over responsibility for the non-
living resources, it is important that the law
ensures people direct influence and
227
involvement in decision-making. "
London Mining should of course feel
committed to these objectives and therefore
do its utmost to fulfill them.
28.14
It is even more Naalakkersuisut commitment
to pursue these objectives and to see the
energy supply for iron mining and aluminum
project in a larger context including the
maximum use of available hydropower
resources of about 400 MW in the area. It is
not Naalakkersuisut obligation to ensure
companies maximized profits when ensuring
that licenses for exploitation and
establishment is given with respect for their
own political objectives.
On the aluminum area process technology
has developed rapidly. Alcoa has already
raised the expected production from the
initial 340,000 tons / year to 400,000 tons /
year after what I have been told, based on a
technology that uses approximately 390
kAmp. There is already production
Comment for the Greenland Government.
BMP: The Government of Greenland is focused on supporting Hydro Power if this is possible in a financial and a technical way. A decision related to the use of Hydro Power also has to be realistic, and therefore it is a must that all these considerations are taking into account when these decisions are taken.
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228
elsewhere in the world on the basis of 440-
technology and testing for time at both 500 -
and 600 kAmp technologies. The increase in
production is hardly proportional, but it can
be expected that Alcoa in a few years will be
able to produce the 340th-400 000 tons /
year with a current capacity of less than the
current 650 MW.
The following long-term solution enabling
Alcoa the option after 15-30 years to have
an even larger production than the 400,000
tons / year. Alcoa has at public meetings and
other occasions often expressed (quote):
"Alcoa will be part of the Greenlandic
society".
Alcoa prides itself on a very high
environmental profile and it should
therefore not be difficult to get Alcoa to
contribute to social and environmentally
sound solution, while taking into account the
companies' commercial interests. If the (t)
south hydroelectric plant is constructed by
another company, it will furthermore reduce
Alcoa's financial burden.
229
28.15 A vision could be the following:
VISION
Naalakkersuisut intermediary - possibly in
collaboration with London Mining and Alcoa
- to form an independent company in charge
of the construction of hydroelectric power
stations in the area, so that both London
Mining and Alcoa can get the required
supply of energy from 2-3 hydroelectric
plants in the area.
There are already very large players in the
area who might be interested, for example,
Statkraft, Vattenfall and Landsvirkjun. DONG
could also be relevant.
Hydroelectric plants are connected in a
coherent network, which for the time being
is sufficient for the iron mine at ISUA and the
aluminum smelter at Maniitsoq. It will
provide greater security for both Alcoa and
the iron mine and hydroelectric power will
already be available at the coast.
In the longer term, when the iron mine is
depleted, Alcoa will have the opportunity for
Comments for the Greenland Government.
BMP: Suggesting regarding an independent company is noted.
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230
even greater supply totaling 500 to 700 MW
or create other energy-intensive industries
at the coastal areas. There has already been
considered hydrogen technology, server
farms, zinc refinery mm
Hoping that Naalakkersuisut and Inatsisartut
- and London Mining and Alcoa - will see
energy supply for large-scale projects in a
broader context.
231
29 Jakob Mathiassen II
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
29.1 The area applied, as shown on the map on the web portal, includes as far as I can see only the northern tip of the Lake 750 (Tailings Pond).
This is a relevant observation. The area applied for should include the entire surface area of Lake 750 since this lake will become a technical part of the project.
DCE/GN: Nothing to add.
The map is not part of the EIA or SIA. No changes to the reports are required. A correction to the licence area application will be forwarded to the BMP by London Mining.
232
30. Departementet for Fiskeri, Fangs tog Landbrug (APNN) – Department of Fiskeries, Hunting and Farming
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA
30.1 The project is situated in a caribou area where professional hunters, leisure hunters and trophy hunters explore caribou in the hunting season. The hunting season is typically from the beginning of August to October. According to section 4.8 in Annex 2 of the EIA caribou in August mainly occur in the flat lowlands in Narsarsuaq, in the valleys of Ilulialik and in Qussuk. There is clearly a conflict of interests between the professional hunters, leisure hunters and trophy hunters and London Mining. According to the EIA caribou is mainly present in the planned port area (Taseraarsuk) from August to April, in the planned mine area (Isuakasia) between June and September, while they occur around the planned airport (west of Kuussuaq in Ilulialik) all year. According to Annex 2 of the EIA a large area northwest of the planned mine area has large number of female caribou with small calves and this area has been appointed “important area for wildlife” by the National Centre of Environment and Energy because of the many calving caribou. The planned road and pipeline between the port and the mine will pass through wintering-, summer- and
The construction of a large mine including over 100 km of road/pipeline and a port facility in a caribou area cannot take place without some disturbance of the animals. In particular the activities during construction of the road/pipeline are expected to have an impact on caribou. However, the construction works will be of limited duration and during operation the disturbance will be much less. For example will the noise impact be much smaller and the mine staff will not be allowed to leave the working areas. Also helicopter traffic will be much less during operation. Based on experience from other mines the EIA report concludes that caribou will be disturbed in a zone 2-5 km wide round the mine facilities. This means that caribou will occur in lower numbers in this zone (but not necessarily be absent). The caribou will probably habituate to the traffic on the road after some years. Disturbance will therefore mainly take place in the zone round the port and – during the first years – along the road through Narsarsuaq and Illulialik. We agree that some of these areas have very lush vegetation but only a very small part of this will be within the disturbance zone. In the EIA we conclude, that hunting will only be affected in a relatively small area and that this is unlikely to have an impact on the caribou population in the area.
DCE/GN recommend that caribou population’s use of the area is monitored, in order to assess whether the proposed mitigation measures are having the desired effect.
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233
calving areas as well as cross paths used by caribou for their annual migration. Noisy activities during the construction phase such as blasting, noise from machines and disturbance from staff that moves around in the area will disturb caribou significantly and they will move to other places. The disturbed areas are lush and particularly important for caribou and it is difficult to identify other areas that are as important to caribou as Taseraarsuk, Narsarsuaq and Ilulialik. According to Annex 2 of the EIA fewer female caribou with calves were observed in the Narsarsuaq-valley in the last years and this could indicate how sensitive the caribou are to disturbance. Surveys and human activities in the area also disturb the animals. It is the hunter’s view that caribou in Ilulialik area already have moved away due to disturbance from helicopters flying much to low and other activities.
It should be noted that the important calving area identified by DCE/NERI is well outside the project area.
30.2
The EIA focuses on sea birds and it is assessed in Annex 3 that the planned project only will have low impact on the sea birds in the area. It is said that shipping in the Godthåbsfjord will not increase significantly, that the vessels will move slowly and keep a distance of 2-3 km from the sea bird colonies. As is also mentioned in the Annex 3 of the EIA the Godthåbsfjord is one of the most important wintering areas for the West Greenland population of Eider
Shipping in the Godthåbsfjord has been assessed to have low impact on breeding sea birds because the weekly vessel, which moves at a speed of only c. 10 knots, will pass the colonies at a distance of several kilometers. This is believed to have little disturbance impact on the nesting and foraging sea birds. The main wintering area for Eider ducks in the Godthåbsfjord is situated at Nipisat Sound near the mouth of the fjord and just across Nuuk. The slow moving vessels navigating along the center line of the fjord will be at least 3 km from Nipisat Sound.
DCE/GN recommend launching a monitoring of seabird uses of the sites along the shipping route. Refers to the document with proposals for monitoring.
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duck (Somateria mollissima). According to the Greenland Red List (2007) this species is assessed as vulnerable and the importance of this area for the entire population is high. This means that disturbance from shipping or pollution such as an oil spill will have large consequences for the eider duck population. Eiders is one of the most hunted sea birds in Greenland and has thereby high cultural value and to some extent also high economical value.
The ships are therefore not believed to disturb the wintering sea ducks at this site. A shipping accident that leads to an oil spill in the fjord can have very severe consequences for wintering eiders. However, navigation of large bulk carriers is a standard practice in the world; maritime regulations are followed by ships companies and the contingency plan and procedure for combating oil spills are in place; the likelihood of a major oil spill that would impact the eiders is deemed to be very low.
30.3
The impacts of the project on the areas terrestrial birds is not prioritized in spite of the fact that several threatened (near threatened and moderate threatened) species occur. Species such as the Greenland White-fronted goose (Anser albifrons flavirostris), Great Northern Diver (Gavia immer) and Harlequin Duck (Histrionicus histrionicus) and mentioned in the EIA under section 0.7.2, 5.3.3 and 7.2.2, but the impacts of these species from the planned project are assessed as low. This is in spite of the fact that the area is an important staging area for migrating Greenland White-fronted geese in spring. Greenland White-fronted geese is an endemic species which means that Greenland has a responsibility to protect this species. The Agreement on the Conservation of African-Eurasian Migratory Waterbirds (AEWA) is currently preparing a management plan for the Greenland White-
All terrestrial birds that occur in the project area are discussed in Annex 1 to the EIA. Special emphasis is paid on species on the Greenland Red List of threatened species. To supplement the literature study and ad hoc field observations two special field studies were carried out (1) mapping and assessment of the importance of spring staging areas for Greenland White-fronted goose in the project area and (2) mapping of breeding Harlequin Duck in the project area. Birds associated with habitats other that the fjord has therefore not been given less emphasis than sea birds. The EIA specifically list a mitigation measure that aims at minimizing the disturbance of Greenland White-fronted geese in spring (“In years when thin snow cover and early snow melting is recorded, the environmental officer will advise London Mining’s personnel on how to keep disturbance of staging Greenland White-fronted geese at a minimum during the first three weeks of May”). Specific mitigating measures are not given
DCE/GN: Nothing to add.
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235
fronted Goose. Although Greenland is not member of AEWA, Greenland has been involved in the preparation of this plan. One of the key points in the plan is that the spring staging areas for the geese must be protected, because it is essential for the geese to find food after migrating across the Inland Ice cap in order to complete the migration to the breeding sites. The planned project will disturb important staging areas. According to the Greenland Red List is one of the threats to the Great Northern Diver, which is assessed as near threatened, disturbance of the breeding grounds from mineral project. However, the report suggests no mitigating measures that can minimize this disturbance. Orbicon’s annex on animals and plants of the project area defines a survey area, but this area does not include the entire project area. It is therefore difficult to assess how many Great Northern Diver nest sites there are in the area and to what extent the birds will be disturbed.
regarding Great Northern Diver because this species mainly breed at large lakes in the lowland where no disturbance outside the port area will take place during the operation phase (the staff will not be allowed to leave the working area). The survey area addressed in Annex 1 only covers the land and port area. An additional survey area that covers the shipping route in the fjord is included in Annex 3.
236
31. Dep. for Indenrigsanliggender, Natur og Miljø (NNPAN)
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA / SIA
31.1 Ancient rocks and traces of life Isua rocks differ from the other very old rocks in Nuuk region in that they are initially formed in the surface environment of the earth. Isua rocks are the oldest and best preserved rocks which can provide information about conditions at the surface of Earth's earliest geological history, which is therefore of great scientific importance. Minik Rosing, from the Natural History Museum, University of Copenhagen has identified 3 sub-areas where the oldest rocks can be found, see attached map. In the EIA this aspect is not explained, despite the fact that NNPAN has clarified this aspect during the scoping phase.
When a mine company applies for permission to initiate exploration activities in an area it is ultimately with the purpose to open a mine. It is therefore the responsibility of the government to ensure that exploration for minerals is not granted in a site where it is considered as a reservation area which pose a significant social, environmental, scientific or other values. Furthermore, the Greenland National Museum has conducted archeological surveys to bring to the project development the necessary inputs and recommendations in this respect. Refer to answer in 11.2. Among the areas of geological importance identified by Minik Rosing sub-area 1 and 2 are situated far from the constructions areas of the Isua project. Sub-site 3 is located c. 2 km south of the processing plant and accommodation site and c. 7 km from the mine pit. A service road and tailings pipeline will go across the site but this will not impact the geological formation per see.
-
None
31.2 Cumulative effects It is in BMP guidance for EIA assumed that an EIA must account for the cumulative
LM and its environmental consultant agree that in addition to an assessment of significant individual
DCE/GN: Nothing to add.
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237
effects. NNPAN notes that the impact of the various projects and components are quantified with and without mitigation measures respectively for the project, but that the total effect of all components of the project are not accounted for. NNPAN considers it appropriate to explain the cumulative effects of the various components of the Isua project, for example the cumulative effects on caribou when the process plant, haul road, runway, harbor, etc. is established and operational. Furthermore, it is relevant that the EIA describes the cumulative effects of the Alcoa's aluminum smelting plant, despite the fact that a decision to realize the project is not yet taken. This assessment shall include cumulative effects associated with disturbance of caribou and the use of water resources in the area. NNPAN notes that the lakes used by Alcoa are in the same area as Lake 750 and Lake 792, as per the attached Appendix Map 2. In case Alcoa project is realized it may imply that the tailings water will follow a different route than the one described in the EIA, page 106-107.
project component, an overall assessment must also be presented. The total effects of the Isua projects are presented in the “Conclusions of the EIA” page 38-41. This also includes the overall impacts of the various project activities on caribou. LM and its environmental consultant are aware of BMP’s requirement to take into account the cumulative effects of other projects in the same area. However, at the Isua iron ore project is the only scheme that has reached a stage where the constructions works have been defined and an application to start building has been submitted to the Greenlandic authorities for approval. It is therefore not possible to assess specific potential cumulative effects of other project, such as the Alcoa since no detailed plans are available or approved. This perception and approach is also in compliance with e.g. the Danish EIA guidelines issued by the Danish Ministry of Environment. In these guidelines cumulating effects are defined as impacts from other existing projects or plants and/or approved projects and plans. (cf. Vejl nr. 9339 “Vejledning om VVM I planloven”).
Impact of caribou
31.3 Use of significance levels in mitigation measure tables, seem unclear. Especially the table "Barrier effect during the operational phase as a result of pipeline with 45 ramps
In the early stage of the EIA, it was assesed that a slurry pipeline would pose a impediment to caribou movements at a regional level. London Mining therefore decided to include caribou
DCE/GN: See answer 30.1. None
238
to passage" is confusing, since significance without mitigation measures is considered to be "low". This is not in line with preceding paragraph of the report, which refers to "the 105 km long road pipeline from the inland ice to the fjord will pose a serious obstacle or a complete barrier to caribou movements at regional level, if not ramps that allow animals to pass are established." Also it is described as mitigation measures that the number, location and design of the ramps should be adjusted, if the results of future monitoring program show a need. NNPAN welcomes the establishment of a monitoring program. NNPAN recommend that the monitoring program shall be adjusted so that it is possible to quickly change the project if it is found that there had to be barrier effects as a result of the project's infrastructure.
crossing ramps as part of the road-pipeline design. When assessing the impact of the barrier effect of the pipeline on caribou without mitigation in the table section 7.2.4 it is therefore takes into account the 45 ramps. The proposed mitigation in the table concerns only if additional ramps are constructed based on future monitoring work.
31.4 In connection with the potential barrier effects NNPAN notes further that in the Annex of the EIA that deals with caribou it is noted that it is a well-known fact the caribou will be scared away from roads and other infrastructure at a distance of 2-5 km to each side. However it is not estimated in the EIA that this disorder affects the caribou more than "medium" because "food supply in the huge neighboring areas is likely to be of the same or almost the same quality." NNPAN would like this presumption to be supported and provided some evidence, as Figure 4-4 and 4-10 in Annex 2 of the EIA shows that it
The disturbance impact at the port and along the road is expected to cause displacement of caribou from a zone extending 2-5 km away. This does not mean that caribou are expected to completely disappear from the zone but to occur in lower density than previous condition. The zone along the road is expected to become very narrow or even disappear as experience from North America show that caribou readily adapt to vehicles on a road. The construction of the Isua project will cause displacement of caribou from important feeding areas at Qussuk and along the road in the Narsarsuaq valley (the first years). The question is
DCE/GN: See answer number 30.1. None
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is precisely Narsarsuaq valley that is the caribou core area in winter, as this is where the biggest food supply exists. Narsarsuaq valley is 8 km wide at its widest point, which means that the animals are potentially being displaced from this important core area. If Figure 2-1, 4-4 and 4-10 are compared it is furthermore shown that a large part of the core area of caribou in study area of the EIA is inaccessible to animals by establishing project infrastructure. In view of the above, NNPAN it is unclear on what basis the disturbance of the animals is considered to be "medium". A more detailed analysis of whether food resources in adjacent coastal areas are sufficient to maintain the animals existence would be desirable. NNPAN also notes that there is no expected impact of the mitigation measures that are proposed in connection with the EIA. For example, the significance of "disturbance of caribou in the construction phase" - without mitigation is considered "medium" and the significance of fact, that "construction work is to be planned so that the calving season is taken into account" and daily planning of the day's work of environmental employee, is also considered "medium "
how large a part of the population that will be impacted and what the consequences will be. Caribou are mainly present near the proposed port site at Qussuk during late autumn and winter (August-April). Caribou that are displaced from the disturbance zone are forced to find food in other areas. Although the Narsarsuaq Valley without doubt is a key area for wintering caribou, other sites with good food supply are available in the region. This includes the Akia-Nordlandet which according to GINR was where most caribou (in the Godthåbsfjord area) spend the winter between 2000 and 2005. The road between the port and the mine site will run along the east edge of the valley for about half of its length. In particular during the construction phase but also in the first years of operation traffic on the road is expected to cause disturbance of caribou in a 2-5 km zone. This disturbance has been assigned “medium” in the EIA. A “medium” impact is defined as causing “decline/displacement of a key animal (such as caribou) at local level” with local defined as 0-5 km (main report page 55-56). If the caribou habituate to vehicle on the road, as is the case in many places in Canada and Alaska, the overall disturbance will be considerably less.
31.5 NNPAN notes that the planned route goes through one of the DCE appointed caribou calving territories and refers in this respect to BMP Field Rules, which states that there should be special consideration in areas of major importance for wildlife.
The pipeline-road corridor will run along the south-eastern border of the calving area designated by DCE and also marginally enter the area. A set of field rules to limit any disturbance will be developed by London Mining in cooperation with the Greenland authorities.
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.
31.6 NNPAN notes that Ivisaartoq is not included in the study area, despite the fact that the animals here are part of Akia- Maniitsoq population and are directly dependent on the study area, including activities in the study area. In the guidelines from BMP for preparation of the EIA it is shown that the entire area affected by a project must be involved in EIA. It is therefore unclear to NNPAN why distribution of Isua project study area does not include the area of distribution of the Akia- Maniitsoq stock of caribou.
LM and its environmental consultant agree that caribou at Ivisaartoq are part of the Akia-Maniitsoq caribou population and that animals from this area migrate into the Isua area at times. When this area has not been specifically mentioned in connection with the assessment of caribou it is because the behavior of caribou from this area is believed to be fundamentally the same as the animals in the Isua area. This means that the impact assessment and proposed mitigations for caribou in the project area will also apply to caribou at Ivisaartoq (and to caribou at the Fiskefjord and Akia-Nordlandet).
DCE/GN assesses that the project will not have a direct impact on the caribou occurring in Ivisaartoq. It is evaluated that inclusion of the site in the EIA would not have led to a different conclusion than the one presented in the submitted.
None
31.7 NNPAN notes that the construction of infrastructure through the most fertile areas together with the fragmentation of caribou core areas could have been avoided if the project had been based on Aninganneq bay. This is shown in Figure 4-4 and 4-10. An assessment of Aninganneq alternative would be relevant proportional to reducing the negative environmental impacts of the project. In the EIA it is stated that Aninganneq at an early stage was abandoned as a result of icebergs in the fjord.
The selection of the port location is addressed in 1.1 above and the comments regarding Caribou are addressed in 30.1 and 31.4.
DCE/GN: Nothing to add. None
The Tailings Pond and the Retention Pond
31.8 NNPAN notes that one wants to deposit slag from the incineration plant in the lake 750. NNPAN can inform that the conclusion of the report, prepared on behalf of the
The recommendations from a 2003 report prepared for the Greenland Home rule is observed. In the said report, the future practice in handling slag and fly ash from incinerators in
DCE/GN will evaluate ”amendment” when final EIA is available.
Amendment to EIA section 6.1.5 and 7.1.5 re.
241
Government of Greenland Possible solutions for the handling of fly ash and slag from 2003 states that the disposal of fly ash and slag should be organized separately, as there is potential for leaching of contaminants, which constitute a potential risk of contamination of the environment. NNPAN also notes that the EIA does not explain how it will handle fly ash from the incinerator. NNPAN recommends that this is to be included in EIA.
Greenland are discussed and recommendations made. It is also noted that the recommendations are adopted by KANUKOKA, namely to separate handling of slag from fly ash. Furthermore, it has been noted that slag might be used for building and construction projects depending on a specific assessment of the slag content. This is in line with the EIA report where slag from incinerator plants is considered to be inert having low potential for leaching of metals and other constituents and therefore should be acceptable to deposit as part of the tailings. The option recommended in the said report of using slag as part of construction projects have been noted (e.g. used for maintenance of the access road). The recommendation to deposit fly ash separately from slag has been noticed. Handling of fly ash will be part of the management of hazardous waste as described in the EIA (section 6.1.5 and 7.1.5). In the EIA it is stated that hazardous waste will comply with regulations and mutual agreement with Kommuneqarfik Sermersooq. The statement will be extended to include fly ash.
fly ash
31.9 NNPAN notes that the water from Tailings Pond (Lake 750) and Lake 792 will run out into the Godthåbfjord. It is noted that monitoring will be established but that mitigation measures for discharge of possibly contaminated water from Tailings Pond is not described.
The water quality (WQ) in the outlet from the Tailings Pond will comply with the authorities’ requirement with high confidence. Refer to answer in 7.1 and 20.2.The WQ is expected to be well below the requirements throughout the operational period especially in the first part of the operational period where the retention time is long. The water quality in the outflow is expected
DCE/GN: Nothing to add. None
242
to gradually change in the operational period as indicated in the EIA report graphs (cf. section 7.1.12). If the WQ develops unexpectedly, a number of technical mitigating measures can be introduced in time avoiding violation of the requirements, e.g. mitigating processing technique, mitigating application of reagents, changed discharge mode of tailings into the lake, or seasonally increase in retention time by means of regulating the outflow, etc. These technical measures are optional and internal tools as part of the mining operation and considered to be outside of the EIA context.
31.10 NNPAN recommend that the section on page 207 "Greenland Water Quality Guidelines – GWQG is explaining that the levels referred to are set by the DCE and thus only applicable as standards for water quality and criteria applicable for mineral resources activities.
The recommendation from NNPAN to make a full citation of the source for the criteria will be adopted i.e. the term used in the BMP Guidelines for preparing EIA reports will be used namely: “Greenland Water Quality Guidelines in connection with mining activities”.
DCE/GN: Nothing to add. Full title of ‘Water Quality Guidelines’ will be used in the EIA (i.e. main report and Annex 7).
31.11 NNPAN notes that "Greenland criteria for water quality" is exceeded by discharges from the Retention Pond. In this context the EIA should clarify how the guiding values have been stipulated, and what the consequences will be for the recipient. In addition, there is a lack of detection of the water exchange in the recipient is sufficient to ensure that there will be an accumulation of toxic substance
The remarks stated by NNPAN (“Greenland criteria for water quality is exceeded”) is based on a mistake by NNPAN. The criteria for water quality are ambient water quality criteria to be fulfilled after dilution in a near field around the discharge point (zone of dilution) and not effluent criteria. The ambient water quality criteria are determined by DCE based on a number of international eco-
DCE/GN: Nothing to add. None
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toxicological assessments and international guidelines as explained in the EIA guideline issued by BMP (please confer the BMP – EIA guidelines, 2011 edition, page 16-19). The practice of determining ambient water quality criteria and convert the criteria to effluent criteria using a dilution factor is an international recognized management principle in administering discharge permits and has also been used for decades in Danish administration. These aspects have been further detailed in the reply to question no. 4 raised at the 3rd public hearing meeting.
31.12 It is argued in the EIA that waterfowl are likely to be attracted to the open water area that will appear when warmer water from the Retention Pond is discharged in Taseraarsuk. The EIA does not address whether these birds will be harmed by staying in the bay, where the emitted reagents above the acute toxic levels and the effect of any oil film transferred to seabirds.
Concentrations of residues of reagents in Taseraarsuk bay influenced by water from the retention pond will be below levels harmful for resting water birds. Fouling of water birds in oily sheens or oily residues in Taseraasuk will not take place during normal operational procedures. Oily residues mixed in waters from the industrial areas (diesel containment berms, maintenance shops, etc) are treated in oil/water separators. Discharge of oily water to the marine environment is not expected during normal operations. If unexpected oil release occur, the oil will be recovered from the retention pond or alternatively in the Taseraasuk Bay as part of the contingency plan. If flocks of birds occur under a spill, mitigating measures will be taken to frighten them away. This measure will be part of the contingency plan.
DCE/GN: Nothing to add. None
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31.13 Assessment of discharges from Retention the Pond should take into account the effect of the total quantity of discharged substances rather than merely focusing on the inferred concentration. Thus, there should be accounted for whether the emitted substances can be expected to degrade in the marine environment, or whether the substances will sediment or bio-accumulate. Moreover, one should carry out an assessment of the impact on total emissions over the mine life expectancy.
Effluents are regulated by the authorities through identification of ambient water quality concentrations and a transition zone. Based hereof the effluent criteria concentrations are stipulated (confer response above and reply no. 4 from 3rd public hearing meeting). The EIA approach is complying with the authorities’ requirements. Only degradable reagents without bio-accumulating properties will be approved by the authorities according to response no. 4 to questions raised at the 3rd public meeting. Estimates of mass transport of water, suspended material and metals from the retention pond can be estimated and compared with natural mass transport from catchment areas to the Godthaabs Fjord. Using available data sources from the catchment area of Kugssua River, the following order of magnitude estimates can be derived. Copper (Cu) is used as example for metal transport. Other metals can be estimated although the overall conclusion is the same as stated below. The estimate does not pretend to be of high accuracy, however, the estimates are considered sufficient for order of magnitude comparisons.
Outlet of filtrate from Retention
Pond to Godthaabs fjord (Qugssuk part)
Outflow Kugssua River to
Godthaabsfjord (Ilulialik part)
DCE/GN will assess question when final EIA is available.
Order of magnitude estimates of mass transport to be included in the EIA Annex 7 and the main EIA.
245
Water quantity per year
7.4 mio. m3/yr 7000 mio. m3/yr
Total Suspended Solids (TSS) concentrations
10 - 15 mg/l* (average under normal operation, range up to 50 mg/l )
150 mg/l** (range up to 520 mg/l)
Mass transport of suspended solids per year
100 tons/yr 1,000,000 tons/yr
Concentration of Cu (dissolved)
2.9 μg/l* 1.4 μg/l**
Concentration of Cu (total / unfiltered)
26 μg/l* 11 μg/l**
Mass transport of Cu per year (dissolved–filter)
20 kg/yr
10000 kg/yr
Mass transport of Cu per year (total- unfiltered)
0.2 t/yr 75 t/yr
Data source: * EIA, Annex 8, SGS Laboratory ageing test, average of 3,7,14,28 days. ** EIA, Annex 7, Field measurements in May and August 2011, outflow of Taserâssuk into Kugssua River.
The figures indicate that the natural mass transport (water and suspended solids) to Godthaabsfjord from the Kugssua catchment area (comprising a minor part of the total run off area to Godthaabsfjord only) are 3 - 4 orders of magnitude larger than the expected mass transport from the retention pond (i.e. a factor of 1000 – 10000). The mass transport of metals from the retention pond is likewise insignificant compared to the natural transport from the Kuggsua River. Taken into consideration that the total run off to Godthaabsfjorden is several times larger than the Kuggsua River part, it underpins the conclusion
246
that the load from the retention pond is insignificant. The above reflections will be included in the EIA.
Dust and air pollution
31.14 NNPAN agrees with the remarks on use of diesel plants rather than hydropower by the Climate and Energy Office. From the precautionary principle and exposition in the EIA on the goal of applying BAT and BEP NNPAN finds it relevant that one uses hydroelectric power rather than diesel power plant.
Comment on hydropower has been detailed previously (cf. response no. 5.1)
DCE/GN: See answernumber 5.1.
None
31.15 The EIA sets out a series of standards for dust and air pollution (EPA standard, IFC standard and EU standard). As it in the EIA is pointed out that there will be use BEP and BAT NNPAN recommend the use of the highest standards of preventive measures against dust and air pollution. NNPAN can state, that the standard practices according to the Environmental Protection Act is a requirement that diesel power plants comply with the Danish limits. This also applies to emergency generators in cities.
US EPA emission standards for non-road diesel engines, for mine equipment and haul trucks, are slightly stricter than EU standards. The US EPA Tier 4 standards (2014) for engines 130 to 560 kW are essentially identical to EU Stage IV standards, but slightly stricter for PM: 0.02 g/kWh vs. 0.025 in the EU standard. EPA has standards for engines > 560 kW but EU does not. EU ambient air quality standards are used in dispersion modelling since they apply throughout Europe. Danish C-values for ambient concentrations are normally applied in dispersion modeling using the OML model. OML could not be used due to the complex terrain. The AERMOD model used does not provide the exact statistic required for evaluation of compliance with C-values, so only the EU ambient limit values could be tested for compliance. World Bank/IFC emission standards for diesel power plants are referenced since the EU Large
DCE/GN: Nothing to add. None
247
Combustion Plant Directive does not apply to diesel engines. Emission limit values in Miljøstyrelsen’s Guidelines for Air Emissions (2001) do not apply to large diesel engines. Danish emission standards in Departmental Order no. 621 of 23/06/2005 could apply, giving a lower NOX emission limit value. The air pollution dispersion modelling assumes World Bank NOX emissions, which makes the dispersion results for NO2 more conservative. The area of NO2 exceedance would be smaller if the Danish emission standards had been used when calculating power plant emissions.
31.16 NNPAN notes that the 105 km long road will be a dirt road and lacks a description of mitigation measures in relation to dust problems, particularly with special reference to the fact that one will run in convoys.
The 105 km access road between the port and the mine processing plan will be an unpaved road constructed with sand, gravel materials excavated from borrows sites and rocks. The road construction will not differ from usual road construction of unpaved roads and there is no environmental concerns related to the material composition. The traffic on the road is estimated to an average of 76 passages per day (EIA, Annex 5) with a speed of max 50 km/h in summer and max. 35 km/h in winter time. Most of the passages will be vehicles in convoys. Dust from this limited number of traffic will not generate dust in large amount; will not be of environmental concern in the vicinity of the road and the issue will not differ from other unpaved roads constructed in Greenland or elsewhere in other Artic regions with limited traffic. In addition, dust generation during the winter months, which can be up to 6- 8 months along the access road, is very limited.
DCE/GN will recommend that dust dispersion along the road is monitored in order to assess possible needs for action, if there are indications of problems.
None
248
“DCE/GN recommendation to monitor dust along the access road is noted. Furthermore, the best international practices for dust control for mining roads will be implemented under the Isua project. While dusting from the access road and haul roads is not an issue during winter time as the surface forms a freezing snow and sand zone, proven techniques will be applied during dry periods. These include various options such as water spray along sensitive portions of the access roads and/or use of dust suppressants which are mixed with water and applied topically to dirt haul roads or unpaved roads. Dust suppressants that are selected and used in the mining industry are environmentally friendly and approved by environmental authorities.
31.17 Decommissioning Plan NNPAN note that the open mine pit may be left as it is when the project is completed and activity areas shut down. NNPAN considers it appropriate that the closure plan is elaborated. According to article Long-term recovery patterns of arctic tundra after winter seismic exploration, 2010, arctic flora, and tundra takes long time to regenerate. This should be taken into consideration in connection with the closure plan.
A preliminary closure plan has been prepared as part of the EIA. The closure plan is further developed as required by the Application on Section 19 and 43 of the Mineral Resources Act. The point about the slow regeneration of arctic vegetation is noted.
DCE/GN: Nothing to add.
None
31.18 Ballast Water Convention NNPAN finds it positive that the Ballast
Comment is a matter for the Government of
BMP: Noted.
None
249
Water Convention will be used despite the fact that it has not yet been ratified and implemented in Greenland.
Greenland. DCE/GN: Nothing to add.
Notes to Annex
31.19 Appendix 3 NNPAN notes that Atlantic halibut are not treated in the Annex section on fish. It must be assumed that Atlantic halibut, foraging in shallow water, including in Qussuq are likely to be affected by the discharge. NNPAN find that discharges influence of halibut and other species should be examined in the EIA.
Orbicon has in connection with the baseline survey in 2010 recorded Atlantic halibut in Godthåbsfjord (but not from Qussuk). This fish species is not discussed in Annex 3 (or elsewhere in the EIA) because focus here is on the key species in connection with commercial and subsistence fishery. The discharges from the project into Qussuq comprise water from the sewage plant and the retention pond. The retention pond will be built to the highest standard and water discharged into the fjord from the plant will not have an impact on fish (or the marine environment in general). Similarly has simulations and analyzed been carried out that show that water from the retention pond will not have any impact on the marine environment outside the Taseraarsuk creek.
DCE/GN: Nothing to add.
31.20 Annex 10 On page 13 it says Niaqornarsuaq Bay which must be Taseraarsuk Bay. NNPAN notes that on page 17 it is not mentioned that there may be found falcon nests within the project area as indicated in the EIA in particular on page 156. NNPAN recommends that there in the section Potential identified impact on socio economic environment is a description of
Noted and will be corrected. It is correct that the falcon nest is not mentioned. But it should be noted that the description of birds in Annex 10 is just a summary and that reference is made to Annex 1 for details. The areas identified as very old geological formations and noted by NNPAN (according to the maps attached the hearing reply) is not in conflict
DCE/GN: Nothing to add.
Niaqornarsuaq Bay is substituted by Taseraarsuk Bay in Annex 10 page 13.
250
the Isua rocks and the importance the areas set out in Annex 1 have on science
with area affected by the open pit mining i.e. the iron ore exploitation. Therefore, commenting these issues under ‘socio-economic’ environment will not add any information to the EIA.
251
32. Peter Barfod
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA
32.1
Hydropower MUST be utilized. Anything else
is completely unacceptable. This is aiming at
establishing a coherent electricity grid
system along the coast. And then in order to
utilize clean renewable energy. As in
Norway. In a way, London Mining is the
cause and the responsible part if there are
problems with the timing. Up to the public
meeting in autumn 2011 it appears on
London Mining homepage that the project
was based on hydropower!
Comment on hydropower is adressed previously
(cf. response no. 5.1).
-
None
32.2
Underground mining must be utilized. As in Kiruna. Provides less dust and better occupational health environment.
The mining method is decided by the overall evaluations of the project feasibility based on the ore and conditions for its mining. Also, it is an unsubstantiated assertion that underground mining creates less dust and better occupational health. The structure and formation of the Isua iron ore deposit makes open pit mining the most attractive and feasible method.
-
None
252
32.3
Olivine deposit at the Fiskefjorden must be used to pellerts production, such as the Cryolite company originally planned. These added value activities should be introduced in Greenland. Anything else is looting. Two years ago one got the right to the mineral rights, so one should not just give it away.
London Mining produces iron concentrate of premium-quality blast furnace grade pellet feed. Pelletizing in Greenland is not an feasible option.
-
None
32.4 Instead of slurry‐pipe lines a conveyor system (Doppelmayr) should be utilized. Alternatively and even better, electric trains as in Kiruna should be used. There is almost energy balance. Transport down with filled ore-train creates so much electricity, that transport up is next to free. Waterborne ore freezes. This is known in Kiruna, therefore they have established a large underground ore loading facilities in Narvik. The so-called Silas project.
The alternative of using a 105 km long conveyor system in a harsh arctic climate is not justified based on technical, environmental or economical considerations compared to a slurry pipeline. The argument of using train as large energy provider is not viable. The pipeline design has taken the cold temperature into consideration. The pipeline is thermally insulated and the slurry will not be frozen over the time when it is transported from the process plant to the dewatering plant.
-
None
32.5 Co-ordinated transport with e.g. Alcoa should take place, so that ballast water is avoided.
ISUA and Alcoa are two different privately owned projects. Each has a different project objectives, shipping location and project schedule. The idea is beyond any realism in the current condition.
None
32.6 This is a matter for Greenland Government.
BMP: Requirements related to heavy
None
253
Heavy fuel oil by shipping should totally be prohibited. This applies all vessels. At the wharf shall be connected to electricity ashore.
Please also confer reply no 12.5, 13.11 and 16.5.
fuel will be set in the government approvals.
32.7
If the Alcoa‐project is realized at all it must be placed in Nuuk. Following recent announcements they should have the fuck finger and Hydro on track again!
Comment is a matter for the Government of Greenland.
BMP: Noted.
None
32.8
8. Hydropower to London mining and Alcoa should be run by an independent company which is independent of the two companies. It could be DONG, Statkraft or Vattenfall. Possibly in a joint company. The Cryolite company was originally the Danish State. They operated with hydropower. There should be no obstacles for the state to come back on track again!
Comment is a matter for the Government of Greenland.
BMP: Noted.
None
32.9
The content of the two newspaper articles is maintained in its entirety. Please confirm reception of hearing response.
The above viewpoints are assumed to be the key comments to be included in the hearing process. The content of the articles have not been considered in details.
None
254
33. Grønlands Politi
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment to EIA/SIA
33.1 BMP has, through the hearing portal on vww.nanoq.gl published the "EIA" and the SIA" of London Mining iron mining project near Nuuk for public consultation. The end of the consultation period was set to 19 October 2012.
By mail of the 19th October 2012 I
announced to BMP that Greenland Police
had not received the reports for
consultation. Thus, BMP informed me on, 23
October 2012, that BMP looks forward to
receiving the responses from Greenland
police within 14 days as also proposed by
me.
I hereby submit my comments on the two
assessments. I must emphasize that my
comments are limited to the issues I believe
are relevant on the impacts on the
environment and social impacts. Allow me,
in this context, to assume that Greenland's
Police will be involved in the ongoing
process on other aspects of the project that
At the scoping workshop a proposed list of
stakeholder were present to the invited selected
stakeholder. The invited stakeholders were agreed
with BMP.
At the workshop it was asked if additional
stakeholders should be included into the SIA
process. At that meeting Greenland’s Police was
not mentioned.
- None
255
may interface with police responsibility.
33.2 Impacts on the Environment In the EIA report section 7.4.3 on pollution of marine habitats a cross-reference is mentioned to section 6.2.8, where the potential contamination of Godthåbsfjorden are discussed. In this context, I have not been able to identify section 6.2.8.
The correct cross-reference is section 6.2.3 of the
main EIA report (and not section 6.2.8).
-
Correction
of the cross-
reference
will be
included in
the EIA.
33.3 According to Act of Inatsisartut No. 14 of 26 May 2010 (Emergency Management Act) § 13 paragraph. 1, the overall combat effort of accidents and disasters is to be coordinated by the police. In this regard I have with satisfaction noted that the EIA states that there must be contingency plans for environmental emergencies in place (e.g. Chapter 9.1 and 9.3). However, I do not find in the assessment or in the appendices (particularly Annex 10) more detailed description of the contingency plans. Based on Annex 10, Chapter 9, a draft contingency plan exists in the Appendix D, which simply refers to a separate file. This file is not published or sent to me.
In this context, I request that draft
contingency plans shall be submitted for
consultation to Greenland Police, and
likewise the Greenland Police would be
A detailed Environmental Management Plan (EMP) will be in place prior to the construction phase and will be revised throughout the project period as appropriate. The EMP will comprise a comprehensive Emergency Response Plan. This is spelled out in the EIA (e.g. section 9).
The Annex 10 of the EIA is a preliminary
framework for the Environmental Management
Plan. The preliminary framework will be further
elaborated immediately after commencement of
the project assuming the project is approved by
the Greenland Government and financing is in
place.
The central role of the Greenland Police in
emergency planning is acknowledged and likewise
the kindly offer to act as advisor in this respect.
- None
256
pleased to participate as an advisor during
the process in elaborating the plan.
Finally, I request that the final plans will be
made available in well before the start of the
project enabling all stakeholders to
familiarize themselves with the plans and
consider exercise activity, etc.
Greenland Police will be involved in planning and
discussing the emergency response plans
throughout the process.
The viewpoints of having the emergency plans in
place and as well as sufficient time for considering
adequate rehearsal exercises before the takeoff of
the activities are acknowledged.
33.4 Social Impact Assessment
The assessment does not include an analysis
in relation to the number of police core tasks
related to the project. It is in this context, an
incomplete assessment without an analysis
of these issues. Allow me to recommend
that such an analysis is prepared as a
supplement to the assessment. Below are a
number of issues which I believe should be
included.
Comments are noted.
-
None
33.5 Chapter 1.3 and 9: From the chapters is shown which authorities and organizations etc, there has been consulted during the SIA process. From this it is shown that the Greenland Police has not been involved. Moreover, it appears that not even the Greenland Command (per 31 October 2012 Arctic Command) has been involved. Since Greenland Command is a
To be taken into account
-
None
257
major player in particular areas for sea rescue, maritime safety and pollution control, allow me to suggest that the command involved.
33.6 Chapter 2.1: From the chapter is stated that the citizens of Greenland " has a Danish passport, which automatically gives them the same rights as Danish citizens". This is after my view, not a correct description, as citizens of Greenland are Danish nationals in exactly the same conditions as nationals of the other parts of the kingdom and thus obviously has a Danish passport.
To be taken into account
-
Citizens of Greenland have Danish nationality which is similar to other nationals of the Danish Kingdom and thus they will have a Danish passport.
33.7 Chapter 2.2.1: From the chapter is shown a list of the main laws that applies for the project. In my opinion, lnatsisartutlov No. 14 of 26 May 2010 (Emergency Management Act) § 13 paragraph could usefully be mentioned in this context.
To be taken into account
-
Law to be added
33.8 Chapter 5.3:
From the chapter is shown a description of
the authorities of the Self-Government and
To be taken into account.
-
A description of the imperial authorities
258
municipalities. In this context is missing in
my view a description of the imperial
authorities, who are important stakeholders
in the project. For example, the Labour
Inspection, Greenland Command, Danish
Maritime Authority, Greenland Justice and
Police.
as the Labour Inspection, Greenland Command, Danish Maritime Authority, Greenland Justice and Police will be included in the SIA.
33.9 Chapter 5.7.3.4: The chapter is, in my opinion inaccurate and contains several factual errors. The chapter includes a very brief description of Greenland Police. The description is not correct, since the police district is divided into 4 police regions, each with a main police station and a number of local police stations. The chapter also describes that in 2014 in Nuuk will open a closed prison. This date is not correct. I will in this context, allow to suggest that there the Probation in Greenland will be addressed for a correct description of the probation conditions. In addition, the chapter "Greenland Supreme Court" that rightfully should be reported as'' High Court of Greenland ", the Supreme Court is one for the whole of unified court located in Copenhagen. Finally, the chapter describes crime in Greenland. Section contains several errors, so I shall suggest
Comment taken into account.
-
A revised
version of
the chapter
will be sent
for
comment to
the Police
before
included in
the final SIA
259
that it undergo a quality control. Greenland Police participates would be happy to assist in this work.
33.10 Chapter 6.3:
The chapter describes the impacts on the
public services during the construction and
operational phases. It is below described
that there will be an increased workload for
immigration authorities regarding the
processing of work and residence permits. I
agree to this assessment. In the same
regard, I recommend that the assessment
should be extended to include resource use
for in and out travel controls during the
construction and operational phases.
Comments noted. and should add an section in
the report
-
A section to
be added to
the SIA
Report
33.11 Chapter 6.4: This chapter describes the social aspects of the project. I have in this relation found that the risk of crime is not covered by the assessment. I must in this connection very much urge to make an assessment of the project's impact on crime for both the crime act and the special acts, which is relevant for the project. As examples of this is the risk of violence, property crimes, violations of environmental, hunting and nature conservation rules violations of the working condition acts and the import and use of illegal substances.
Comment taken into account
-
This will be
included in
the SIA
Report.
260
33.12 Other: In the SIA is not an assessment of the rescue ability of authorities to carry out initiatives under construction and operational phase in mine area with the associated land and on vessels going to and from the area. I take the liberty to recommend that such an assessment should be made.
Comment taken into account.
-
A section to
be added to
the SIA
Report
261
34. DCE/GN comments to the EIA for the ISUA project
No. Question Response from London Mining Response from BMP and/or DCE/GN Amendment
to EIA/SIA
34.1 DCE/GINR notes that on the background of the forwarded comments will London Mining carry out eco-toxicological tests of water from the pipeline and tailings. London Mining will develop a test protocol. It should be noted that the water must be representative and include realistic maximum concentrations of reagents and metals.
No respond required - None
34.2 DCE/GINR notes that London Mining in a new note has explained the composition of drainage water from the area where waste rock will be deposited.
No respond required - None
34.3 DCE/GINR notes that London Mining has explained in a satisfactory way the number of samples for which geological and chemical tests has been carried out as well as their representativeness.
No respond required - None
34.4 DCE/GINR notes that London Mining has changed the wording in the EIA regarding shipping to Nuuk and in the Godthåbsfjord. It should be noted that shipping in the
No respond required - None
262
Godthåbsfjord will increase significantly.
34.5 DCE/GINR notes that London Mining has modified the wording in the EIA and has prepared a supplementary note on emissions of SO2, NOx, sod and greenhouse gasses. It should be noted that the emissions are significant compared to other emissions in Greenland.
No respond required - None
34.6 DCE/GINR has noted that London Mining has addressed the risk of possible oil spills. It should be noted that London Mining indicate that they will follow international and national regulations but that London Mining will not voluntarily introduce that ships calling in at the project port must not use heavy oil.
No respond required - None
34.7 DCE/GINR notes that London Mining based on DCE/GINR’s comments has expanded the description of the Godthåbsfjord included the section on the occurrence of whales in Godthåbsfjord and have addressed the potential impact on wildlife.
No respond required - None
34.8 DCE/GINR notes that London Mining based on comments from DCE/GINR has moved the outlet of wastewater from Niaqornarssuaq bay to Taseraarssuk. It should be noted that Taseraarssuk already will be impacted by the port and the associated shipping.
No respond required - None
34.9 DCE/GINR notes that the description of the marine fjord-system in the main EIA report has been modified to include the references Orbicon has been provided with and that these references have been included in the document. As far as DCE/GINR can assess
No respond required - None
263
there has not been carried out specific surveys and the composition of species belonging to the benthic fauna. Reference is made to video takes but this does not necessarily provide information on the benthic species that occur at Qussuq and Taseraasuk.
34.10 DCE/GINR notes that London Mining has expanded the description of the contents of some of the reagents that are planned to be used in the various processes. It should be noted, however, that the information of the content of reagents/chemicals is still not complete. London Mining has expressed that detailed information on the content of reagents/chemicals will be required from the producers/suppliers before an agreement will be made with producers/suppliers
No respond required - None
34.11 DCE/GINR notes that London Mining agrees that limits should be defined for the contents of reagents/chemicals in process-water and wastewater and that on-line monitoring should be established that provides on-going information on the contents in processwater and wastewater. In addition, any the potentially harmful substances to the environment in reagents/chemicals must be substituted. It should be noted that it can be necessary to purify the processwater and wastewater including the water discharged from the
No respond required - None
264
retenstionspond.
34.12 DCE/GINR notes that London Mining has clarified a number of questions regarding the retentions pond, including the contents of suspended material.
No respond required - None
34.13 DCE/GINR notes that London Mining does not expect that the discharge to the marine environment will lead to a coloration of the fjord or that flocculation will take place when wastewater mixes with salt water in the fjord.
No respond required - None
34.14 DCE/GINR notes that London Mining will continue to establish the background levels of metals, nutritiens etc. in freshwater after the permission has been granted and during the construction phase.
No respond required - None
34.15 DCE/GINR notes that BMP has explained that London Mining intent to continue to study the option of constructing a hydropower plant as part of the project.
No respond required - None
34.16 DCE/GINR notes that London Mining agrees that a study is carried out of the vegetation and occurance of rare plant species along the remaining section of the road corridor and the designated borrow sites where materials will be extracted fro roads, bridges etc.
No respond required - None
34.17 DCE/GINR notes that London Mining agrees that the (location of ) facilities and construction works should be considered on the basis of (the distribution of) the
No respond required - None
265
vegetation and rare plant species.
34.18 DCE/GINR notes that London Mining in the EIA has changed definition regarding vegetation and plants.
No respond required - None
34.19 DCE/GINR notes that London Mining adequately has modified the description of the utilisation of the area by caribou and has re-assessed how big an area that will be impacted by the project.
No respond required - None
34.20 DCE/GINR notes that London Mining will ensure that monitoring on the projects impact on caribou will be carried out.
No respond required - None
34.21 DCE/GINR notes that London Mining has prepared a supplementary note regarding underwater noise and the risk of collisions with whales and that the EIA has been corrected regarding the number of ships. It should be noted that the note is general and that the noise assessment is a rough estimate. The increase in shipping and noise from shipping will in parts of Godthåbsfjord increase significantly, in particular from the large ships that are part of the project. It is the opinion of DCE/GINR that detailed noise measurements should be carried as well as monitoring of whales in the Godthåbsfjord before shipping starts in order to determine the baseline levels. Noise measurements and noise modelling will be important tools in connection with the development of a monitoring program of potential impacts from the project on whales and other marine mammals in the Godthåbsfjord.
No respond required - None
266
34.22 DCE/GINR notes that London Mining has provided additional information regarding the 400 tonnes of dust which can be dispersed in connection with the loading of iron concentrate to the ships. In the reply London Mining has explained that the 400 tonnes per year is a maximum value and that the dust control measures that will be imposed will reduce the amount of dust that will be dispersed to the environment. It should be noted that the dust deposition can be considerable in the port area and that the impact of the dust and its contents is unknown. Monitoring of dust and its content should be part of the monitoring program.
No respond required - None
34.23 DCE/GN notes that London Mining has responded on DCE/GINR comments regarding implementation of EU-thresholds for effects of NO2 and SO2 on vegetation and Arctic plants.
No respond required - None
34.24 DCE/GINR notes that London Mining in the planning and implementation of the construction works will take potential problems with erosion into account.
No respond required - None
34.25 DCE/GINR notes that London Mining has no comments to the letter from DCE/GINR dated 15 June 2011 with comments regarding monitoring principles and the development of a monitoring program. The criteria for the monitoring carried out by the mine companies will be agreed in connection with the finalization of the exploitation licence. BMP in cooperation with DCE/GINR will carry out continuous
No respond required - None