Whitebook Hearing Responses from the Hearing Portal for .../media/Nanoq/Files/Attached Files/Raastof... · 201/Referat% 20Borger m% C3% B8de% 20I_dk.ashx) But it not shown in details

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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

4

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


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

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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)


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.


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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


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.


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


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

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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.


14

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

15

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


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.


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

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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.

19

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.


20

7. Knud Seblon


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


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.


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


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.


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.


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.


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.


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.


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


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.


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.


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


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.


None

42

13. ICC og WWF


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.


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.

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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







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

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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.


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.


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).


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


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

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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.

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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.


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.


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.


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


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


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


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.


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


-

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.


-

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


-

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


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.


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


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.


None

80

monitoring should be done in close

cooperation between the company and

health authorities.

81

16 TIMMIAQ


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


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.


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


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.


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.


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


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.


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



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 ... "



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.



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


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.


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


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


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.


work on contingency planning.


meeting (24. September 2012).

BMP: Contingency and emergency

related issues will be regulated in the


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


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



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


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.



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,


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.


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.

None

115

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.


noted

18.24 Other comments "Kommuneqarfik Sermersooq want to be an

The comments and statements by Kommuneqarfik

None

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


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?


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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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


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


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


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


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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


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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.


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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.


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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

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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


BMP: requirements can be set in the government approvals or be a part of the IBA negotiations.

None

148

guaranteed the same rights.

149

21. Nuuk Fjords Venner


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?


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."



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



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


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


BMP: Noted. DCE/GN: This is not an environmental aspect.

None

http://bmp.gl/minerals/application-and-reporting-forms

http://bmp.gl/minerals/application-and-reporting-forms

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.


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


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.

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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


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 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 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

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.

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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.

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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.


-

‘Sikkerhed til søs’ is the correct Danish term.

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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.


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


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To 5.3.2. "Social and Human Life" and "Technology and the Environment".

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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

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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

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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.


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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.


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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

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None

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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.


The non

technical

summary

section 0.1

amended

with

information

re. ‘non-

western’

workers

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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.

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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


None

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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.

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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


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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


The conclusion from the BFS

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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

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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.

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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.


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.

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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

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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.

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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).


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


181

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.


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.


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.


None

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24 A. KANOKOKA (Bilag A – Qaasuitsup Kommunia)


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)


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


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


BMP: There is a continuously evaluation of the hearing process in order to have this improved.

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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


BMP: There is a continuously evaluation of the hearing process in order to have this improved. Comment referring to the consultation period is noted.

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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.



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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.



None

25.6 Sustainability / environmental impact

In the coalition agreement the principle of

sustainability is stressed in the following


BMP: Noted.

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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

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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

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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.

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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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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


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.

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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.


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

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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?


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.

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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?


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.

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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.


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).

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26. Avataq


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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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

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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.

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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


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.

None

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


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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209

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)


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.

- None

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.

- None

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

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28. Jacob Mathiassen


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.


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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:

214

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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215

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

-

None

217

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


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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

- None

http://www.stat.gl/dialog/main.asp?lang=da&version=2011&link=EN&subthemecode=t7&colcode=t

http://www.stat.gl/dialog/main.asp?lang=da&version=2011&link=EN&subthemecode=t7&colcode=t

220

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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222

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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223

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.


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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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226

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.


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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.

None

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


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.


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


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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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.

None

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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


None

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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.

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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


None

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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

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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.


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.

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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


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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-


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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.


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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.

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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


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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

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“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.


None

31.18 Ballast Water Convention NNPAN finds it positive that the Ballast


BMP: Noted.

None

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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.


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


Niaqornarsuaq Bay is substituted by Taseraarsuk Bay in Annex 10 page 13.

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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.

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32. Peter Barfod


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!


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!


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


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.


-

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.


-

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


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.


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.


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


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.


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.


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.


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.


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


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


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


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.


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.


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.


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.


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.


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


265

vegetation and rare plant species.

34.18 DCE/GINR notes that London Mining in the EIA has changed definition regarding vegetation and plants.


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.


34.20 DCE/GINR notes that London Mining will ensure that monitoring on the projects impact on caribou will be carried out.


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.


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.


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.


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.


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


267

monitoring of the terrestrial and aquatic environment.

Documents

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