Revised Final Environmental Study Report (24 MB) - Gold Canyon ...

SPRINGPOLE GOLD 

ACCESS CORRIDOR PROJECT 

FINAL ENVIRONMENTAL STUDY REPORT 

JULY 2013 

Gold Canyon Resources Inc. 

Suite 810 – 609 Granville Street 

PO Box 10356 Pacific Centre 

Vancouver, B.C. V7Y 1G5 

Tel: 604.682.3234 

Fax: 604.682.0537 

www.goldcanyon.ca


Springpole Gold Access Corridor Project 

Final Environmental Study Report 

TABLE OF CONTENTS 

1.0 Introduction ...................................................................................................................... 1 

1.1 Location and Land Tenure ...................................................................................... 2 

1.2 History ..................................................................................................................... 2 

1.3 Objective and Justification for Project .................................................................... 3 

1.4 Scope of the Report and Notice to Readers ........................................................... 5 

2.0 Assessment of Alternatives ............................................................................................. 6 

2.1 Assessment of Alternative Methods ....................................................................... 6 

2.2 Assessment of Alternative Locations ...................................................................... 7 

2.2.1 Western Corridor 7 

2.2.2 Eastern Corridor 13 

2.2.3 Selection of Preferred Alternative 18 

3.0 Consultation and Required Approvals for Project ......................................................... 20 

3.1 Aboriginal Communities ........................................................................................ 20 

3.1.1 Cat Lake, Slate Falls and Lac Seul First Nations 20 

3.1.2 Wabauskang First Nation 23 

3.1.3 Métis Nation of Ontario 25 

3.1.4 Protection of Aboriginal Values and Sensitive Sites 25 

3.1.5 Skills Transfer and Capacity Building Initiatives 26 

3.1.6 Measures to Protect Aboriginal and Treaty Rights 27 

3.2 Public Stakeholders .............................................................................................. 29 

3.2.1 Pre-2012 Consultation 29 

3.2.2 Project Consultation 29 

3.3 Government .......................................................................................................... 35 

3.4 Regulatory Approvals Process ............................................................................. 35 

3.4.1 Provincial 35 

3.4.2 Federal 36 

4.0 Environmental Setting .................................................................................................... 37 

4.1 Current Land Use and Archaeological Values ..................................................... 38 

4.2 Climate .................................................................................................................. 39 

4.3 Surface Waters ..................................................................................................... 39 

4.4 Ground Water ....................................................................................................... 40 

4.5 Soils ....................................................................................................................... 40 

4.6 Terrestrial Plant and Animal Life ........................................................................... 40 

4.7 Aquatic Plant and Animal Life ............................................................................... 41 

4.8 Local Air Quality, Noise and Light ......................................................................... 41 

4.9 Socio-Cultural Setting ........................................................................................... 41 

5.0 Project Description ......................................................................................................... 43 

5.1 Construction .......................................................................................................... 44 

5.2 Operation, Maintenance and Surveillance ............................................................ 50 

5.2.1 Road Use Strategy 51 

5.3 Decommissioning .................................................................................................. 52 

6.0 Potential Effects and Mitigation Measures .................................................................... 54 

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6.1 Potential Negative Effects Requiring Additional Mitigation Measures ................. 54 

6.2 Process to Determine Compensation for Proximal Tourism Operators ............... 56 

6.3 Viewscape at Birch River Crossing ....................................................................... 56 

6.4 Habitat Fragmentation .......................................................................................... 57 

7.0 Significance of Residual Negative Effects ..................................................................... 58 

8.0 Monitoring and Implementation ..................................................................................... 61 

8.1 Routine Monitoring ................................................................................................ 61 

8.1.1 Timber Harvesting and Water Crossings 61 

8.1.2 Species at Risk Monitoring 62 

8.2 Triggered Monitoring ............................................................................................. 62 

9.0 Closing Remarks ............................................................................................................ 62 

10.0 Path Forward for Springpole Gold Project ..................................................................... 63 

LIST OF TABLES 

Table 2-1: Effects Analysis for Western Corridor ........................................................................ 9 

Table 2-2: Effects Analysis for Eastern Corridor ....................................................................... 14 

Table 2-3: Summary of Effects Analysis for Proposed Corridors .............................................. 18 

Table 3-1: Summary of Comments and Concerns from Aboriginal Communities .................... 28 

Table 3-2: Issues Management Matrix ...................................................................................... 32 

Table 3-3: Summary of Supportive Comments ......................................................................... 34 

Table 6-1: Supplemental Mitigation Measures for Potentially Significant Negative Effects ...... 55 

Table 7-1: Generic Significance Criteria Considerations and Levels of Significance ............... 59 

Table 7-2: Significance of Residual Negative Effects ............................................................... 60 

LIST OF PHOTOGRAPHS 

Photograph 1-1: Summary of Historical Exploration Activity ....................................................... 1 

Photograph 1-2: Aerial View of Camp Site .................................................................................. 3 

Photograph 5-1A: Typical Winter Road Cross Section ............................................................. 48 

Photograph 5-1B: Typical Primary Road Over Winter Road Cross Section ............................. 49 

Photograph 5-2: Flowchart to Illustrate Road Decommissioning Timeline ............................... 53 

Photograph 6-1: Modified Alignment of Birch River Bridge ....................................................... 57 

LIST OF FIGURES (in Appendix 1) 

1-1 Property Location Plan 

2-1 Location of Alternative Corridors (shows major water crossings) 

2-2 Future Proposed Extension of Wenasaga Road 

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APPENDICES 

Appendix 1 Figures 

Appendix 2 Letters from Horizon Archaeology (September 2012 and December 2012) 

Appendix 3 Public Stakeholder Registry 

Appendix 4 Biological Constraints Report for Springpole Gold Access Corridor Project 

Alternatives Assessment (DST, 2013A) 

Appendix 5 Field Report from DST (DST, 2013B) 

Appendix 6 Recommendation from Equi-Knox Environmental Regarding Process for 

Assessing Compensation to Proximal Outfitters 

Appendix 7 Engineering Details of Proposed Water Crossings and Construction Methods 

Appendix 8 Summary of Comments Arising from Community Consultation Sessions with 

Protocol Nations 

Appendix 9 Submission from Trout Forest Tourism Operators on Final ESR dated February 

2013 

Response to Trout Forest Tourism Operators Comments on Final ESR dated 

February 2013 

Appendix 10 Summary of Potential Measures to Achieve an Overall Benefit to Woodland 

Caribou 

Definition of Terms and Acronyms 

Advanced Exploration: As defined in O. Regulation 240/00 (as amended). With respect to the 

Project, this would include the following types of work: 

Excavation of material in excess of 1,000 tonnes; 

 

Surface stripping on mining lands where the surface area over which the 

surface stripping is carried out is greater than 10,000 square metres, or where 

the volume of surface stripping is greater than 10,000 cubic metres, except 

where all of the following are satisfied: 

i. Surface stripping is carried out in two or more separate areas on the 

mining lands. 

ii. The edges of each area where surface stripping is carried out are 

separated by a minimum of 500 metres. 

iii. In each area where surface stripping is carried out, 

-the surface area over which the surface stripping is carried out is 

not greater than 10,000 square metres, and 

-the volume of surface stripping is not greater than 10,000 cubic 

metres. 

AOC / Area of Concern: As defined by the Ministry of Natural Resources in MNR (1988) and 

MNR (2010). This is a buffer that is reserved along watercourses to prevent effects to the 

watercourse from the inland development. Specifically, the buffer is intended to minimize the risk 

of sedimentation; provide future inputs of coarse woody material; mitigate the effects of harvesting 

on water temperature, water circulation and inputs of fine organic material; mitigate the effects of 

forest management operations on hydrological linkages between aquatic and terrestrial 

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ecosystems; maintain some shoreline forest as residual habitat and dispersal corridors; manage 

some shoreline forest to create some early to mid-successional riparian habitat. AOC also refers 

to buffers surrounding biological values and sensitive areas. 

Where AOC prescription in the FMP is referred to, it is intended to mean that GCU will adhere to 

the FMP 14 - Area of Concern Operational Prescriptions in the current approved 2009-2019 FMP 

on the Trout Lake Forest. Setbacks refer to reserves required for values on the Trout Lake Forest 

as outlined in FMP 14. Furthermore, GCU has agreed to follow Domtar’s proposed FSC protocol 

for the Trout Lake Forest. 

AWS: Annual work schedule; used in reference the AWS of the approved Forest Management 

Plan (“FMP”) for the Trout Lake Sustainable Forest License (“SFL”). 

Base Case Project Description Report: This refers to the July 2012 GCU publication titled 

Springpole Exploration and Access Corridor Project. This document was prepared to facilitate 

consultation regarding the proposed Project herein as well as the on-going Springpole Gold 

Project. 

Chance Find Procedure: There is always a possibility of deeply buried, undetected 

archaeological remains existing in an area. If such materials are encountered during Project 

excavation activities, GCU will immediately stop construction and contact: 

the Ministry of Tourism and Culture at 416-314-7452; 

 

 

 

 

 

Cat Lake First Nation Band Office; 

Slate Falls First Nation Band Office; 

Lac Seul First Nation Band Office; 

Wabauskang First Nation Band Office; 

Métis Nation of Ontario; and 

Licensed professional archaeologist Dr. David Slattery at 705.474.9864, or a qualified 

alternate. 

GCU will work with a licensed professional archaeologist to implement appropriate mitigation 

measures to protect any encountered materials of archaeological significance, in accordance with 

prescriptive standards and guidelines for consultant archaeologists from the Ministry of Tourism 

and Culture. 

In the event that human remains are encountered during excavations, GCU will immediately stop 

all work in the area and contact the local Police Department, the Ministry of Tourism and Culture at 

416-314-7452 and the Registrar or Deputy Registrar of the Cemeteries Regulation Unit of the 

Ministry of Consumer and Commercial Relations at 416-326-8393. 

This Chance Find Procedure will be included in field work contracts for the Project and in the site 

orientation program to ensure it is effectively communicated to all contractors and personnel. 

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Deposit: Mineralized deposit(s) at Springpole Property. Currently, this is known to comprise the 

East Zone, the Main Zone and the Portage Zone, further defined at www.goldcanyon.ca . 

Exploration and resource definition work is currently in progress and this on-going work may 

expand these known zones and identify new zones. For the purpose of this document, this term is 

used to define the known zones and future potential zones. 

DFO: Department of Fisheries and Oceans 

DST: DST Consulting Engineers 

EA: Environmental Assessment 

Eastern corridor: The eastern corridor alternative shown on Figure 2-1. This corridor is the 

preferred alternative access corridor. 

ESA: Endangered Species Act. 

ESR: Environmental Study Report, as required for a Category C undertaking and as defined in 

MNR (2003). 

Exploration: Exploration, or mineral exploration, is the process of finding ore (i.e. commercially 

viable concentrations of minerals) to extract for a profit. Although it involves mineral prospecting, 

the process of mineral exploration and economic evaluations of mineral deposits is much more 

involved, requiring the involvement of a variety of professionals and the management of 

compliance with applicable government legislation. Commonly applied rules of thumb suggest that 

one in every 10,000 mineralized occurrences advance to a positive economic evaluation and 

become a mine. 

Exploration techniques are divided into “advanced exploration” and “preliminary exploration.” 

FAP: Forestry aggregate pit, containing aggregate that may be utilized on forestry access roads 

only. The governing policy is available at the following link: 

http://www.mnr.gov.on.ca/stdprodconsume/groups/lr/@mnr/@forests/documents/document/27558 

8.pdf 

FMP: Forest Management Plan, used in reference to the current Trout Lake Forest Management 

Plan and also the forthcoming 2014-2019 Trout Lake Forest Management Plan. It is 

acknowledged that the current FMP extends from 2009-2019, but the second half of the planning 

period commences in 2014. In this document the 2014-2019 FMP reference is often used to refer 

to the second half of the FMP, which governs the extension of the Wenasaga Road. 

FMP Approved Road: This term is used to refer to the existing Wenasaga Road as well as the 

extension that is approved for construction in the 2014-2019 Trout Lake Forest FMP (refer to 

Figure 2-1) and as may be constructed according to post-2019 FMPs (refer to Figure 2-2). 

FOIP: Forest Operations Inspection Program 

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FRI: Forest Resource Inventory 

FRL: Forest Resource License (to harvest Crown owned timber), issued pursuant to Crown Forest 

Sustainability Act. 

FSC: Forest Stewardship Council is an international not for-profit, multi-stakeholder organization 

established in 1993 to promote responsible management of the world’s forests. 

GCU: Gold Canyon Resources Inc. 

GRN: Generator Registration Number, as defined in Environmental Protection Act and ancillary 

guidance documents. 

Horizon: Horizon Archaeology 

Intensified exploration: This term is used herein to illustrate the fact that the current level of 

exploration intensity is inadequate to define the Deposit and complete a comprehensive economic 

evaluation in a reasonable timeframe. Previously in 2012, GCU has been able to support four (4) 

diamond drills and GCU’s ability to support more exploration activity is marginal due to the 

currently limited access. By comparison with other resource definition projects in Canada that 

have year-round access, these other potentially large tonnage near surface mineral deposits are 

being drilled by >12 diamond drills and are being exposed (i.e. overburden being removed) for 

mapping and bulk sampling. In order to define the Deposit and complete an economic evaluation 

in a timely manner, GCU needs to conduct intensified drilling of the Deposit compared to what is 

currently achievable due to the limited access and also the resulting high logistics costs. Although 

this is subject to change depending on on-going exploration results and data interpretation, the 

current planned area of intensified exploration is shown on Figure 2-1. 

km: Kilometre(s) 

LCC: Local Citizen’s Committee, used in reference to the LCC for the Trout Lake Forest. 

LIDAR: Light Detection and Ranging is an optical remote sensing technology that can measure 

the distance to, or other properties of a target by illuminating the target with light, often using 

pulses from a laser. This technique is commonly used to generate detailed topographic maps. 

LRIA: Lakes and Rivers Improvement Act. 

m: Metres 

Mine: As defined pursuant to the Ontario Mining Act. 

MNDM: Ontario Ministry of Northern Development and Mines 

MNO: Métis Nation of Ontario 

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MNR: Ontario Ministry of Natural Resources 

MOE: Ontario Ministry of the Environment 

MOL: Ontario Ministry of Labour 

MOU: Memorandum of Understanding 

MT: Million tonnes 

NGO: Non-governmental organization 

NHIC: Natural Heritage Information Centre 

NRVIS: Natural Resources and Values Information System 

PEA: Preliminary economic assessment 

Potentially significant negative (residual) effect: This is defined as a negative effect listed in 

Table 2-2. Table 2-2 is generally consistent with the guidance provided in Section 3 of MNR 

(2003). 

Preliminary exploration (techniques): Exploration techniques that do not constitute Advanced 

Exploration, as defined in O. Regulation 240/00 (as amended). Generally, these comprise surface 

diamond drilling holes of various diameters, geophysical surveys, outcrop washing and mapping, 

channel samples, limited removal of overburden (i.e. material that overlies bedrock) and material 

(i.e. overburden and/or bedrock) excavation. 

Project: The Springpole Gold Access Corridor Project. The Project consists of the components 

listed in the bullets below. 

Construction 

Winter time harvesting of timber within the 10 to 15 metre wide eastern access corridor 

(harvesting window of October 15 to May 15, to be confirmed with MNR during approvals 

process that follows the EA process). 

Establishment of winter operational road within the eastern access corridor. Timber that is 

harvested would be used as corduroy for the road, with stumpage paid to the Crown. 

Installation of a modern, monitored gate at the end of the FMP Approved Road (as shown 

in Figure 2-1) to effectively restrict access beyond the FMP Approved Road. 

Water crossings along the eastern corridor would be built to a primary road standard to 

facilitate future potential upgrades of the winter operational road to an all-weather access 

road (by GCU or by other proponents) at a later date and also to minimize environmental 

risk associated with less robust water crossing structures. 

Decommissioning of historic mineral exploration trails, as indicated in Figure 2-1. 

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Operation 

Exclusive use of road by highway vehicles, primarily during winter months (~November 1 

to ~March 15, contingent on weather conditions). 

Infrequent use of road by off-road, low-ground pressure equipment to move materials 

during summer months with the intent of avoiding use during caribou calving periods as 

further described in Section 5.2. 

Discontinue the seasonal ice road over Birch Lake, which will reduce access to Birch Lake. 

Decommissioning 

Proceed with decommissioning of road beyond the FMP Approved Road, unless a 

provincial EA has been initiated for the development of the Deposit during the three (3) 

year period of use following the conclusion of the construction phase. The road would 

continue to be used during the EA for the development of the Deposit. If the provincial EA 

concludes that the Deposit should not be developed, the road beyond the FMP Approved 

Road will be decommissioned. If the provincial EA concludes that the Deposit should be 

developed, the road will remain and be subject to the EA and approvals process for the 

development of the Deposit. The timeline for road decommissioning is described further in 

Section 5.3. 

Gravel placement over this winter operational road and upgrading it to an all-weather access road 

is not part of the currently proposed Project. Pending continued positive exploration results and 

on-going consultation, the gravel placement that would be required to upgrade this winter 

operational road to an all-weather access road may be proposed at a later date. 

The Springpole Gold Access Corridor Project is a subset of the Springpole Gold Project, as 

defined herein. 

Property: Springpole Property, as approximately defined in Figure 1-1. The Property comprises 

the patents and the adjoining mining claims held by GCU. GCU has acquired additional mining 

claims to include the northern portion of the Wenasaga Road where the access corridor is 

proposed. GCU is in the process of leasing selected mining claims in accordance with Section 81 

of the Mining Act. 

Protocol Nations: Cat Lake First Nation, Slate Falls First Nation and Lac Seul First Nation. 

Report: The final Environmental Study Report for the proposed Springpole Gold Access Corridor 

Project (“Project”). 

Residual (negative) effects: The negative effects, after mitigation measures are applied. These 

are described in Section 6. The significance of the residual effects is described in Section 7. 

ROW: Right of way. The ROW for the access corridor is intended to be 15 metres. 

RSA: Resource Stewardship Agreement. 

SAR: Species at Risk, as defined by MNR. 

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SFL: Sustainable Forest License, used in reference to the Trout Lake SFL. 

SGR: Silvicultural ground rules, as defined in an approved Forest Management Plan. 

Springpole Gold Project: The on-going exploration and definition of the mineral resources at the 

Property, as described at http://www.goldcanyon.ca/s/Springpole_Gold.asp?ReportID=535882. 

The Springpole Gold Project includes the seasonal installation of an ice-road over Birch Lake until 

a land-based access corridor is established. Once a land-based access corridor is established, 

the seasonal ice road over Birch Lake will no longer be constructed. The assessment of 

alternative land-based access corridors is the subject of this ESR. 

TFTO: Trout Forest Tourism Operators 

UTM: Universal Transverse Mercator. 

VEC: Valued environmental component (biophysical or socio-cultural environmental components). 

Western corridor: The western corridor alternative shown on Figure 2-1. 

WFN: Wabauskang First Nation 

References 

Bridge, S., Watt, W.R., Lucking, G. and Naylor, B., (Bridge et al), 2000. Landscape Analysis 

for Forest Management Planning in Boreal Northeastern Ontario. OMNR Northeast 

Science and Technology Unit, 36 p. 

Cat Lake First Nation, Slate Falls Nation, and Ontario Ministry of Natural Resources (Cat Lake 

Fist Nation et al.), 2011: Cat Lake – Slate Falls Community Based Land Use Plan, 

“Niigaan Bimaadiziwin” – A Future Life. 

Department of Fisheries and Oceans (DFO), 1995. Freshwater Intake End-of Pipe Fish Screen 

Guideline 

DST Consulting Engineers Inc. (DST), 2013A. Biological Constraints Report for Springpole Gold 

Access Corridor Project Alternatives Assessment. Prepared for Gold Canyon Resources 

Inc. 

Gustafson, E.J. and Crow, T.R., 1994. Modeling the effects of forest harvesting on landscape 

structure and the spatial distribution of cowbird parasitism. Landscape Ecology 9: 

237-248. 

Gustafson, E.J. and Crow, T.R., 1996. Simulating the effects of alternative forest management 

Strategies on landscape structure. Journal of Environmental Management 46:77-94. 

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Harris, L. 1984. The Fragmented Forest: Island biogeography theory and the preservation of 

biotic Diversity. University of Chicago Press, Chicago. 

Konze, K. and McLaren, M., (Konze and McLaren), 1997. Wildlife Monitoring Programs and 

Inventory Techniques for Ontario. Ontario Ministry of Natural Resources. Northeast 

Science and Technology. Technical Manual TM-009. 139 pp. 

Ministry of Natural Resources (MNR), 1988. Timber Management Guidelines for the 

Protection of Fish Habitat. 

Ministry of Natural Resources (MNR), 1995. Environmental Guidelines for Access Roads and 

Water Crossings. 

Ministry of Natural Resources (MNR), 1996. MNR Guidelines For Culverts Installed in the 

Winter. 

Ministry of Natural Resources (MNR), 2003. A Class Environmental Assessment for MNR 

Resource Stewardship and Facility Development Projects. 

Ministry of Natural Resources (MNR), 2010. Forest Management Guide for Preserving 

Biodiversity at the Stand and Site Scales. 

Ministry of Tourism and Culture (MTC), 2011. Standards and Guidelines for Consultant 

Archaeologists 

Racey, G., A. Harris, L. Gerrish, E. Armstrong, J. McNicol and J. Baker (Racey, et al), 1999. 

Forest management guidelines for the conservation of woodland caribou: a landscape 

approach. MS draft. Ontario Ministry of Natural Resources, Thunder Bay, Ontario. 69 

pp. 

Rosenburg, K.V and Raphael, M.G, .1986. Effects of forest fragmentation on vertebrates in 

Douglas For forests in J. Verner, M.L. Morrison and Ralph C.J., Wildlife 2000: 

Modelling habitat relationships of terrestrial vertebrates. Pp 263-273, University of 

Wisconsin Press, Madison. 

Spies, T. A., Ripple, W.J. and Bradshaw, G., (Spies et al.), 1994. Dynamics and pattern of a 

managed coniferous forest landscape in Oregon. Ecological Applications 4:555-568. 

Weir, J. and Johnson, E.A., 1998. Effects of escaped settlement fires and logging on forest 

Composition in the mixedwood boreal forest. Canadian Journal of Forest Research 

28:459-467. 

Wright, D. and Hopky, G., 1998. Guidelines for the Use of Explosives in or Near Canadian 

Fisheries Waters. Canadian Technical Report of Fisheries and Aquatic Sciences 2107. 

www.ontarioliberal.ca/OurPlan/pdf/ruralnorthern/north_platform_mini.pdf 

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Executive Summary 

This Environmental Study Report (“Report”) is required pursuant to MNR (2003) for the Springpole 

Gold Access Corridor Project (“Project”). Gold Canyon Resources Inc. (“GCU”) is the sole 

proponent for this Project and is currently seeking to further define the significant gold resource at 

the Springpole Gold Project in a safe, timely and cost-effective manner so that a comprehensive 

economic evaluation can be completed during the current period of strong gold prices. 

This Report summarizes the processes that GCU has undertaken to comply with the requirements 

of MNR (2003) for a Category C environmental assessment. 

Land Use 

The use of the lands within and adjoining the Springpole Property (“Property”) is generally 

wilderness / recreation, tourism and natural resource extraction (i.e. mineral development, remote 

tourism, forestry). The Property is located in the Trout Lake Forest Sustainable Forest License 

area and has been subject to a great deal of preliminary exploration activities on an intermittent 

basis since the 1920s. This historic exploration activity has resulted in a network of exploration 

trails and minor disturbance in the region due to diamond drilling, linecutting, trenching and 

surface stripping. Domtar currently holds the SFL for the Trout Lake Forest and is active in the 

region. The planned extension of the Wenasaga Road, scheduled to be constructed in the 2014- 

2019 timeline according to the 2009-2019 Trout Lake Forest Management Plan (“FMP”), traverses 

the southeast portion of the Property. 

Environmental Setting and Site Description 

Through extensive biological and archaeological assessment work under direct participation of 

First Nation technicians, GCU has generally defined the locations of biological and archaeological 

values. GCU has planned the proposed Project to avoid these sensitive areas. 

The region is within the Churchill Caribou range and the area is subject to management for 

woodland caribou. 

Project Objective and Justification 

The Project is intended to provide safe, reliable, year-round, land-based access to the area of the 

Deposit (via highway and/or off-road vehicles). This improved access is required for the reasons 

listed in the bullets below. 

 

 

 

Facilitate on-going site infrastructure improvements and the necessary exploration and 

resource definition work on the Springpole Gold Project to support a timely economic 

evaluation of the Deposit during the current cycle of strong gold prices. 

Improve safety and emergency response capabilities. Unfortunately, injuries and fatalities 

on ice roads are commonplace throughout Canada. The GCU team incurred a fatality in 

2005 when a piece of heavy equipment fell through the ice road over Birch Lake (ice road 

shown on Figures 1-1 and 2-1). As well, air access cannot always be relied upon due to 

weather. In the event of a critical injury, reliable land-based access is required to ensure 

that the casualty is safely moved as quickly as possible to hospital care as opposed to 

being weathered in at GCU’s camp on the north shore of Springpole Lake (refer to Figure 

2-1). 

The proposed Project is a subset of the Springpole Gold (resource definition) Project. 

Therefore, the Project is aligns with provincial government objectives related to supporting 

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responsible mineral development and encouraging the responsible development of new 

mines, as further described in Section 1.1. 

Alternatives Assessment and Selection of Preferred Alternative 

GCU evaluated a western and an eastern access corridor in general accordance with Section 3 of 

MNR (2003). The eastern access corridor has been selected as the preferred alternative and it is 

shown on Figure 2-1. This selection has been made in general accordance with MNR (2003) and 

also for the reasons listed in the bullets below. 

Approximately 50% of the eastern access corridor is already approved in the 2014-2019 

FMP and is within the 2011 wildfire area. 

Reduced risk of impacts to archaeological values and major water crossings compared 

with the western corridor, as described herein (refer to Appendix 2). 

Potential synergies with future potential forestry roads planned for the region and a 

potential all-weather road to Cat Lake First Nation. 

Reduced potential for habitat fragmentation and cumulative effects in the region compared 

to the western corridor which would be a further linear development in addition to the FMP 

Approved roads in the vicinity of the eastern corridor. 

Project Description 

The proposed Project consists of the components listed in the bullets below. 

Construction 

Winter time harvesting of timber within the 10 to 15 metre wide eastern access corridor 

(harvesting window of October 15 to May 15, to be confirmed with MNR during approvals 

process that follows the EA process). 

Establishment of winter operational road within the eastern access corridor. Timber that is 

harvested would be used as corduroy for the road, with stumpage paid to the Crown. 

Installation of a modern, monitored gate at the end of the FMP Approved Road (as shown 

in Figure 2-1) to effectively restrict access beyond the FMP Approved Road. 

Water crossings along the eastern corridor would be built to a primary road standard to 

facilitate future potential upgrades of the winter operational road to an all-weather access 

road at a later date (by GCU or by other proponents) and also to minimize environmental 

risk associated with less robust water crossing structures. 

Decommissioning of historic mineral exploration trails, as indicated in Figure 2-1. 

Operation 

Exclusive use of road by highway vehicles, primarily during winter months (~November 1 

to ~March 15, contingent on weather conditions). 

Infrequent use of road by off-road, low-ground pressure equipment to move materials 

during summer months with the intent of avoiding use during caribou calving periods. 

Discontinue the seasonal ice road over Birch Lake, which will reduce access to Birch Lake. 

Decommissioning 

Proceed with decommissioning of road beyond the FMP Approved Road, unless a 

provincial EA has been initiated for the development of the Deposit during the three (3) 

year period of use following the conclusion of the construction phase. The road would 

continue to be used during the EA for the development of the Deposit. If the provincial EA 

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concludes that the Deposit should not be developed, the road beyond the FMP Approved 

Road will be decommissioned. If the provincial EA concludes that the Deposit should be 

developed, the road will remain and be subject to the EA and approvals process for the 

development of the Deposit. The timeline for road decommissioning is described further in 

Section 5.3. 

Gravel placement over this winter operational road and upgrading it to an all-weather access road 

is not part of the currently proposed Project. Pending continued positive exploration results and 

on-going consultation, the gravel placement that would be required to upgrade this winter 

operational road to an all-weather access road may be proposed at a later date. 

The Project is a subset of the Springpole Gold Project, as defined herein. 

This Project proposal is independent of the activities that are approved in the Trout Lake FMP. 

The costs for the proposed road would be borne solely by GCU and there are no co-proponents of 

the Project. 

The Project is regarded as a simple and routine project that has been commonplace in Ontario for 

decades. Mitigation measures to mitigate potentially negative effects are well-proven and long 

established. Mitigation measures have been integrated into the Project execution plan for ease of 

implementation and enforcement by MNR. Additional, specific mitigation measures that are based 

on conventional mitigation techniques are described herein to mitigate potentially negative effects 

to Aboriginal communities, remote tourism operators, local stakeholders, Species at Risk and the 

Churchill caribou range. 

Mitigation Measures 

GCU has undertaken an assessment of the effects associated with the Project in accordance with 

Section 3 of MNR (2003) and these are summarized in Section 2. All effects that were assessed 

as negative are included in Table 6-1 for specific, supplemental mitigation measures beyond those 

that have been integrated directly into the Project execution plan provided in Section 5. 

GCU tracks issues regarding all its activities related to the Springpole Gold Project to facilitate 

efficient management and mitigation of issues that arise due to GCU’s activities. The current 

issues management matrix is presented in Table 3-2. The matrix is dynamic and will evolve for the 

life of the Springpole Gold Project. Although this environmental assessment relates to the 

proposed road and the on-going exploration activities are outside the scope of this environmental 

assessment, GCU will reasonably mitigate the negative effects that are within GCU’s ability to 

mitigate and these mitigation measures are described herein for completeness. 

Public Consultation 

GCU is committed to continuing the consultation process with the relevant stakeholders in the 

region, as identified by the provincial government and by GCU. GCU provides a working draft 

issues management matrix in Table 3-2 to facilitate the tracking and resolution of issues related to 

the Springpole Gold Project. 

Aboriginal Consultation 

GCU continues to engage Aboriginal communities under the guidance and direction of the Ontario 

government. GCU is committed to on-going meaningful engagement with Aboriginal communities 

regarding the Project. 

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1.0 INTRODUCTION 

GCU is a growing mineral exploration company that is focused on the Springpole Property 

(“Property”) area. The Property has a long exploration history and has been explored intermittently 

for gold since the 1920s. This historic exploration activity has resulted in the presence of exploration 

trenches (overburden stripped to bedrock) and a network of mineral exploration trails within the 

Property to provide access for linecutting, trenching, limited surface stripping and diamond drilling. 

GCU obtained the Property in 1998 and has explored the Property and expanded its land position 

since that time. Historic exploration activities are summarized in Photograph 1-1. 

Photograph 1-1: Summary of Historical Exploration Activity 

The identified zones at the Property are currently GCU’s primary asset. GCU released a resource 

estimate on the Property in February 2012, in accordance with National Instrument 43101 

guidelines, which outlined just under four (4) million ounces of gold and 16.5 million ounces of silver 

in the inferred category (includes 1.2 million ounces of gold and 4.8 million ounces of silver in the 

indicated category). Following the publication of the Draft ESR, GCU released an updated resource 

estimate in October 2012 in accordance with National Instrument 43101 guidelines. This updated 

resource outlined a 4.41 million ounces of gold and 23.8 million ounces of silver in the indicated 

category and an additional 0.69 million ounces of gold and 2.7 ounces of silver in the inferred 

category. The press release is available at http://goldcanyon.mwnewsroom.com/pressreleases/gold-canyon-updates-springpole-resource-tsx-venture-gcu-201210170826823001. 

As 

evidenced by this resource estimate, the 2012 drilling program was very successful at increasing the 

confidence in the Deposit by converting inferred ounces to indicated ounces and also increasing the 

overall size of the Deposit. Having defined a multi-million ounce resource that is expected to be 

expanded with further diamond drilling, the Springpole Gold Project is regarded as a highly 

prospective resource definition project rather than a preliminary, grassroots exploration project. A 

July 2013 Page 1




positive preliminary economic assessment (“PEA”) has been completed by an independent, qualified 

consulting firm. The press release is available at: http://goldcanyon.mwnewsroom.com/pressreleases/gold-canyon-resources-inc-preliminary-economic-a-tsx-venture-gcu-201303250862158001 

GCU is currently publicly traded on the Toronto Stock Exchange. The head office of the company is 

located at: 


PO Box 10356 Pacific Centre 

Vancouver, B.C. V7Y 1G5 

Tel: 604.682.3234 

Fax: 604.682.0537 

www.goldcanyon.ca 

The primary GCU contact person for the purpose of this Report is provided below. 

Denise Saunders 

Manager of Community Relations and Lands 

Phone: 807.735.1050 

denise.saunders@bell.net 

denise@goldcanyon.ca 

1.1 Location and Land Tenure 

The Property is located in northwestern Ontario, approximately 110 km northeast of Red Lake (refer 

to Figure 1-1). The Property is located in unorganized township, Red Lake Mining District, Casummit 

Lake Area within the Trout Lake Forest Sustainable Forest License. The Property consists of more 

than 300 mining claims (including 30 patents and 6 leases, covering an area of over 80,800 acres or 

34,900 ha) and extends from the north end of Springpole Lake to Hydro One’s E1C electricity 

transmission corridor via the Wenasaga Road of the Trout Lake Forest (refer to Figure 1-1). To 

facilitate potential future development, GCU is leasing strategically positioned mining claims, 

pursuant to Section 81 of the Mining Act. The significant investment and commitment by GCU to this 

Deposit are evidenced by the forthcoming applications to lease many of the mining claims within the 

Property. 

The Property is primarily fly-in access using float plane or helicopter. Seasonal access has been 

available on an annual basis via a seasonal ice road over Birch Lake that is in use for ~3 to 4 weeks 

per year and extends from the South Bay Mine road (refer to Figure 1-1 and 2-1). South Bay Mine 

Road connects with Highway 105 near Ear Falls. Access is frequently required to move 

consumables, personnel and equipment. All garbage that is generated at the tent camp is flown offsite 

or removed from site while the ice road is available for disposal at an approved landfill. 

1.2 History 

Previous preliminary exploration work on the Property has comprised surface diamond drilling, 

geophysical surveys, geological mapping and exploration trail development. Supporting 

infrastructure that is currently in place on the patents that adjoin the north shore of Springpole Lake 

includes a ~50 plus person tent camp with cookhouse, best-in-class sewage treatment system, 

domestic water supply, storage, heli-pad and ancillary laydown areas. In 2012, four (4) drills 

July 2013 Page 2




generally operated on the Project to continue definition work on the Deposit. Photograph 1-2 below 

is a northward view of the camp site on the north shore of Springpole Lake. 

Photograph 1-2: Aerial View of Camp Site 

Baseline environmental and archaeological studies are currently ongoing. GCU and its consultants 

are endeavouring to scope and conduct these studies in collaboration with the government agencies 

in order to complement the on-going data collection programs being carried out by government staff. 

As well, GCU is continuing to utilize technicians from Cat Lake, Slate Falls and Lac Seul First 

Nations to complete baseline and archaeological field programs (refer to Section 3). Outreach has 

been initiated with Wabauskang First Nation and the Métis Nation of Ontario regarding opportunities 

to work together on the on-going values assessment and baseline program. 

1.3 Objective and Justification for Project 

The objective of the Springpole Gold Access Corridor Project (“Project”) is to provide safe, reliable, 

year-round, land-based access to the area of the Deposit (via highway and/or off-road vehicles). 

This improved access is regarded as justifiable for the reasons listed in the bullets below. 

 

Facilitate on-going site infrastructure improvements and the increasingly intensive 

exploration and resource definition work on the Property to facilitate a timely economic 

evaluation of the Deposit during the current cycle of strong gold prices. 

July 2013 Page 3




 

Improve safety and emergency response capabilities. Unfortunately, injuries and fatalities on 

ice roads are commonplace throughout Canada. The GCU team incurred a fatality in 2005 

when a piece of heavy equipment fell through the ice road over Birch Lake. As well, air 

access cannot always be relied upon due to weather. In the event of a critical injury, reliable 

land-based access is required to ensure that the casualty is safely moved as quickly as 

possible to ambulance and hospital care as opposed to being weathered in at the camp. 

The proposed Project is a subset of the Springpole Gold (resource definition) Project. GCU regards 

the Springpole Gold (resource definition) Project, and therefore the proposed Project, as justifiable 

for the reasons summarized in the bullets below. 

 

 

 

Continued exploration is good for the economy: Contingent on continued successful 

exploration results leading to future financing, the on-going, near-term exploration and 

resource definition work would result in annual expenditures on the order of millions to tens 

of millions of dollars. Based on experience to date, at least two thirds of these expenditures 

would accrue to the surrounding region and bolster the local economy. With the demise of 

the forestry sector in Ontario over the past 10 years and since the stock market crash of 

autumn 2008, promoting economic development in northern Ontario has been the focus of 

federal, provincial and municipal government initiatives, policies and legislative reforms. 

Springpole Gold Project is aligned with provincial government objectives: Ontario 

recognizes the importance of mineral development opportunities to northern Ontario, as 

summarized in the bullets below. 

In the 2011 publication titled “Forward. Together: The Ontario Liberal Plan for 

Northern Ontario,” the current Liberal government has published an objective 

of opening at least eight (8) new mines in the next 10 years 

(www.ontarioliberal.ca/OurPlan/pdf/ruralnorthern/north_platform_mini.pdf ). 

Section 2.3.8(g) of The Growth Plan for Northern Ontario (2011), developed 

pursuant to Ontario’s Places to Grow Act, provides for “enabling new mining 

opportunities.” 

If the Springpole Gold Project proceeds to development and production, a producing 

mine is good for the economy: A producing mine would be significant to the local 

economy and taxation base. While the actual characteristics of potential future production 

will be defined in the PEA, benchmarking of other large tonnage, surface gold mining 

projects across the province suggest that the construction phase jobs would be on the order 

of >500, the production phase jobs would be on the order of >250 and the capital cost for 

the project would be on the order of $500 million. The employment created would likely 

represent a >10% increase in the current total primary and manufacturing industry 

employment level in the Red Lake / Ear Falls region and, to a lesser extent in more distant 

communities including Sioux Lookout, Dryden and Kenora. The provincial and federal 

governments would be principal beneficiaries, through new revenues generated through 

employee income taxes and other employee-related government-mandated contributions 

(e.g. to Canada Pension Plan, Employment Insurance Program, Employee Health Tax and 

Workplace Safety and Insurance Board). These senior levels of government would also 

enjoy additional revenues through value-added sales, corporate income, capital and other 

taxes levied on the corporation. The most proximal municipalities of Ear Falls and Red Lake 

July 2013 Page 4




have expressed support for the Project (refer to Table 3-2). These benefits do not include 

the charitable donations, infrastructure upgrades and voluntary contributions to the local and 

Aboriginal communities that are commonplace with large scale resource development 

projects once a revenue stream is achieved, in accordance with the tenets of modern 

corporate social responsibility. 

Although significant work has been completed to evaluate the known mineralized zones on the 

Property, a deposit of this scale and setting typically requires hundreds of thousands of metres of 

additional drilling before a comprehensive economic evaluation (i.e. bankable feasibility study) can 

be completed, financing can be obtained and a production decision can be made. Given the 

currently limited access to the Property, given the >30% reduction in available monies for exploration 

work due to the currently high logistics and support costs, the timeline for completing the required 

drilling is greater than ~10 years and the ability to finance continued exploration work is at risk. 

Improved access will reduce this timeframe for defining the Deposit and completing a 

comprehensive economic analysis. The current slow rate of progress and reduced ability to define 

significant expansions to the Deposit in a timely manner hinders GCU’s ability to raise the venture 

funding that is required to carry out the much-needed exploration work to facilitate a robust 

economic evaluation. As well, the cyclical nature of commodity prices may result in materially 

depressed gold prices within this ~10 year period, which would deflate the economics of the 

Deposit, reduce GCU’s ability to raise the capital to develop a mine and effectively halt the Project 

for the foreseeable future. 

1.4 Scope of the Report and Notice to Readers 

The Project triggered the requirement for a Class EA pursuant to MNR (2003), due to the proposed 

disposition of Crown resources. This Report has been prepared to comply with requirements for a 

Category C environmental assessment, pursuant to MNR (2003). As is typically the case with 

environmental assessments, this Report contains Project details that are based on preliminary 

engineering rather than detailed engineering. Further field investigation is planned of the preferred 

alternative that emerges from this EA process so that the applications for the permits that are 

required to carry out the Project may be refined. The preferred alternative is the eastern corridor 

alternative, as presented on Figure 2-1 and described in Section 2.2.3. The eastern corridor 

alternative shown on Figure 2-1 is a 500 m wide right-of-way. GCU proposes to construct the ~15 m 

wide road corridor within this right-of-way based on refinements that are made to the road during the 

approval process that follows the EA process. 

As indicated in GCU’s Base Case Project Description Report that was published in July 2012, the 

Draft ESR published in October 2012 and the Final ESR published in February 2013, the on-going 

exploration activities at the Property are outside the scope of this environmental assessment. 

However, GCU notes that it has fundamentally altered its proposed activities in the region to mitigate 

potential impacts that have been identified to GCU. Specifically, GCU has abandoned Advanced 

Exploration techniques (e.g. surface stripping, bulk sample) in favour of less-invasive preliminary 

exploration techniques (e.g. surface diamond drilling). GCU has confirmed with its outside 

consultants that further work using preliminary exploration techniques will be sufficient to define the 

resource and complete a comprehensive economic evaluation of the Deposit. 

GCU tracks issues regarding all its activities related to the Springpole Gold Project to facilitate 

efficient management of issues that arise due to GCU’s activities and implementation of mitigation 

July 2013 Page 5




measures. Rather than excluding any issues from public disclosure that are outside the scope of this 

EA process, all identified issues are listed in Table 3-2 herein along with GCU’s impact mitigation 

measures. GCU shall continue to comply with regulatory requirements and best practices for the ongoing 

exploration and resource definition activities at the Springpole Gold Project that are outside 

the scope of this EA process. 

This final ESR describes a proposed project that has been refined from the Base Case Project 

Description of July 2012, the draft ESR of October 2012 and the Final ESR of February 2013. As is 

evident upon review of these documents, GCU notes that the proposed Project in this Report has 

been fundamentally altered and its duration shortened in an effort to mitigate potential impacts to 

values and interests in the region. 

This Report is intended to be read in its entirety and is not intended to have excerpts read, quoted or 

interpreted out of context. 

The FMP Approved Road (refer to Definition of Terms and Acronyms) is shown on Figure 2-1 and is 

approved for construction by the SFL holder as part of the current FMP, regardless of GCU’s 

actions. For the purpose of comparing the effects of the western and the eastern corridors, it is 

assumed that the FMP Approved Road is in place. In other words, the comparative effects analysis 

is effectively a comparison of the entire western corridor with the eastern corridor road that is 

situated beyond the FMP Approved Road (refer to Figure 2-1). 

2.0 ASSESSMENT OF ALTERNATIVES 

An alternatives assessment has led to the formulation of the proposed Project, as presented in this 

Report. As indicated in Section 1.3, the objective of the Project is to provide safe, reliable, yearround, 

land-based access to the area of the Deposit to support the intensified exploration and 

definition work that is required to support an economic evaluation. 

2.1 Assessment of Alternative Methods 

The alternative methods for establishing reliable year-round (land-based) access to the vicinity of 

the Deposit are listed in the bullets below. 

 

 

 

 

Option 1: Continued fly-in access (helicopter and float plane) with seasonal ice road access 

in February over Birch Lake (weather dependent). This Option is equivalent to the “donothing” 

alternative and assumes that access to the Project continues “as-is.” 

Option 2: Construct the planned Wenasaga road (as approved in 2014-2019 FMP) and 

establish seasonal barge access to the Springpole Gold Project site via Springpole Lake 

during open water period and seasonal ice road access during the winter freeze-up period 

(weather permitting). 

Option 3: Establish a land-based access corridor that connects with the existing road 

network of the Trout Lake Forest. 

The Springpole Gold Project is a very prospective resource definition project. The proposed 

Project is a necessary subset of the Springpole Gold Project. A “no-go” option was not 

included in this assessment given the alignment of the Project with the province’s objectives 

of supporting mineral exploration and encouraging the development of new mines (refer to 

Section 1.1). 

July 2013 Page 6




The criteria listed in the bullets below were considered to evaluate each of the three (3) above noted 

options. 

Do they provide a viable solution to the problem or opportunity to be addressed? 

Are they proven technologies at the scale required and in the timeframe required (design, 

procurement, commissioning)? 

Are they technically feasible at the scale required and in the timeframe required? 

Are they consistent with other planning objectives, policies and decisions? 

Are they consistent with government priorities? 

Could they affect any sensitive environmental features? 

Are they practical, realistic financially and economically viable for the Springpole Gold 

Project? 

Are they within the ability of the proponent to implement (land tenure, financial requirements, 

approvals, patented technology)? 

Are they appropriate to the proponent doing the study? 

Are they able to meet the requirements of MNR (2003)? 

The following bullets summarize the pertinent results of the preliminary qualitative assessment of the 

above noted alternatives for establishing improved access to the exploration site. 

Option 1 

Option 1 is not capable of meeting the objective of reliable year-round land-based access to 

the area of the Deposit. 

Option 2 

Option 2 is not capable of meeting the objective of reliable year-round land-based access. In 

addition, the potential for conflicts with recreational users and effects to water quality due to 

accidents (i.e. spills) are regarded as a significant risk. 

Option 3 

This option meets the objective of reliable year-round, land-based access to the area of the 

Deposit. 

Option 3 is the only alternative that meets the objective of year-round, land-based access to the 

Deposit and will be carried forward into Section 2.2 (assessment of alternative locations). 

2.2 Assessment of Alternative Locations 

The alternative access corridors that were assessed include the western corridor and the eastern 

corridor. These corridors are presented on Figure 2-1 in Appendix 1. 

DST (2012) provides a description of the environmental setting of the Project area as well as a 

comparative biological effects assessment of both access corridor alternatives. This report also 

describes measures to mitigate potential negative effects and it assumes that these are 

implemented for the purpose of determining the significance of residual negative effects. 

2.2.1 Western Corridor 

A general description of this alternative, along with its significant advantages and disadvantages, is 

provided in the bullets below. 

July 2013 Page 7




 

 

 

 

This corridor is a southerly-trending road corridor on the west side of Springpole Lake that 

connects with existing forestry road network to the south (refer to Figure 2-1). 

The western corridor meets the objective of reliable year-round access to the area of the 

Deposit. Given the approved 2014-2019 FMP road to the east, the increased potential for 

cumulative effects to biological values, remoteness values and archaeological values in the 

region are emphasized with this option (refer to letter dated December 2012 from Horizon 

Archaeology to Appendix 2). 

This corridor would increase the likelihood of unwanted access directly to Birch Lake 

compared to the eastern corridor. 

If the Springpole Gold Project proceeds to production, environmentally progressive planning 

would require the mine site to be situated within one (1) watershed rather than straddling 

multiple watersheds to the extent practical. In the event that a production phase is proposed, 

this corridor does not lend itself well to a compact mine site within a single watershed that 

overlies and branches off to access the various mine site features. Furthermore, in order to 

minimize the overall development footprint on the landscape it would be desirable to have 

the access corridor overlap with the mine site features and this corridor alternative does not 

lend itself well to this sort of progressive planning. 

An analysis of the effects (positive and negative) associated with this alternative was undertaken in 

accordance with Section 3 of MNR (2003) and is presented in Table 2-1. Unless otherwise stated in 

Table 2-1, this analysis assumes that conventional, proven mitigation measures are applied to the 

alternative in accordance with applicable guidance documents from MNR and DFO that are 

referenced herein. 

July 2013 Page 8




Net Effect 

Screening Criteria Negative Effect (1) Positive Effect (1) 

Nil Unk 

High Med Low Low Med High 

Natural Environment Considerations 

Table 2-1: Effects Analysis for Western Corridor 

Comments and Rationale 

Air quality X 

Maintain equipment in accordance with manufacturer recommendations. No material impacts associated with the Project are 

anticipated (fugitive dust, emission from combustion equipment). 

Water quality or quantity X 

Road development and installation of water crossings and eventual decommissioning would conform to the MNR and DFO guidance 

documents referenced herein, as well as AOC prescriptions in the FMP. Erosion and sediment control plan to be developed and 

followed, as per MNR (1995). Post construction FOIP audit and monitoring post construction is planned, as per Section 8. This corridor 

requires 11 water crossings, one of which is a clear span bridge over the Birch River (refer to Figure 2-1 for major crossings). 

Species at risk or their 

habitat 

Significant earth or life 

science features 

Fish or other aquatic 

species, communities or 

their habitat (including 

movement of resident or 

migratory species) 

Land subject to natural 

or human made hazards 

X 

X 

X None identified to date. 


The access corridor would be a linear development through a relatively un-developed area within the caribou range, with known calving 

lakes near the south end of the proposed corridor and at the south end of Springpole Lake, as shown in Figure 2-1. Refer to DST 

(2012) in Appendix 4 and DST (2013) in Appendix 5 for further discussion. 

Through installation of modern, monitored gates, there should be minimal increased public access to lakes, which would increase 

fishing pressure. Road development and installation of water crossings and eventual decommissioning would conform to the MNR and 

DFO guidance documents referenced herein, as well as AOC prescriptions in the FMP. 

Recovery of a species 

under special 

management program 

X 

The access corridor would be a linear development through a relatively un-developed caribou range, with known calving lakes near the 

south end of the proposed corridor and at the southwest end of Springpole Lake, as generally shown on Figure 2-1. Refer to DST 

(2012) in Appendix 4 and DST (2013) in Appendix 5 for further discussion. 

Ecological integrity X 

The access corridor would be a linear development through a relatively un-developed area. Regionally, this corridor would exert 

greater cumulative effects because it would effectively duplicate the access roads to the east being built by the SFL holder. 

Terrestrial wildlife 

(including numbers, 

diversity and movement 

of resident or migratory 

species) 

X 

Potential for an increase in road mortalities of a variety of terrestrial wildlife species. This threat has the potential for mitigation and is 

dependent on the intensity of road use. 

Natural vegetation and 

terrestrial habitat 

linkages or corridors 

through fragmentation, 

alteration and/or critical 

loss 

X Refer to Section 6.4. 

Permafrost X Not applicable. 

July 2013 Page 9




Net Effect 

Screening Criteria Negative Effect (1) Positive Effect (1) 


Nil Unk 


Soils and sediment 

quality 

Drainage or flooding X 

Sedimentation or erosion X 

Release of contaminants 

in soils, sediments 

Natural heritage features 

and areas (e.g. areas of 

natural and scientific 

interest, provincially 

significant wetlands) 

X Road development and installation of water crossings and eventual decommissioning would conform to the MNR and DFO guidance 

documents referenced herein, as well as AOC prescriptions in the FMP. Water crossings and cross-culverts would be to primary road 

standards, cross-drainage culvert locations demarcated in the field by independent road consultant. Erosion and sediment control plan 

to be developed and followed, as per MNR (1995). Post construction FOIP audit and monitoring post construction is planned, as per 

Section 8. 

X 


Other (Potential for 

introduction of invasive 

exotics) 

X 

Measures will be implemented to mitigate this risk (use appropriate seed for re-vegetation that contains no exotic species, use local 

contractors & equipment). 

Land Use, Resource Management Considerations 

Access to trails or 

inaccessible areas (and 

water) 

X 

Public access will be same as in the FMP due to use of modern, monitored gate at the end of the FMP road. Beyond the FMP-road, 

access will be gated and restricted to GCU personnel, Crown employees, their agents and stakeholders with MNR approval to use the 

road (e.g. tourism outfitter, commercial bait fisherman). In the event of unwanted access, this corridor has a greater risk of providing 

direct access to Birch Lake. 

Obstruct navigation X Comply with approval from Transport Canada for any approvals to cross a navigable water (Birch River). 

Obstruct other resource 

management projects 

X No synergies with future roads planned by SFL holder, which creates a larger cumulative impact and could negatively affect the 

permitting process of the SFL holder. 

Traffic patterns or traffic 

infrastructure 

X 

Access would be restricted by a modern, monitored gate. No synergies with future roads proposed by SFL holder. This option would 

introduce traffic into an area of the Trout Lake SFL where there would otherwise be no traffic. 

Recreational 

importance-public or 

private 

X 

Remoteness of the area would be negatively impacted. This corridor is through a less developed region and would result in a greater 

cumulative impact for the region because it would duplicate the FMP-approved access corridor. Refer to Table 3-2 for management 

strategy and mitigation measures. This alternative would increase potential unwanted access to Birch Lake. It is noted that this could 

be a positive effect if there are lodge owners seeking to convert to a drive-in mode of operation or landowners seeking the ability to 

drive to their property. GCU acknowledges that the road could be a positive impact if access were allowed by MNR. Access could also 

be a negative impact to local landowners desiring remoteness and no increased access to the area. 

July 2013 Page 10




Net Effect 

Screening Criteria 

Or create excessive 

waste materials 

Or commit a significant 

amount of a nonrenewable 

resource (e.g. 

aggregates, farm land) 

Noise levels X 

Negative Effect (1) Positive Effect (1) 

Nil Unk 


X 

X 


Project would not create excessive waste materials. Waste from the exploration site would continue to be containerized to avoid 

attracting wildlife and shipped off-site for disposal at a MOE approved facility. 

Minor amount of aggregate from FAPs and GCU’s patented land to be utilized for water crossings associated with road. This would not 

result in increased resource scarcity for other aggregate users. The only other aggregate user is the SFL holder and any aggregate 

removed from FAPs will be used on the FMP Approved Road. 

Noise impacts will be highest during the construction phase, which is planned during winter months to avoid active period of tourism 

operators, caribou calving window and breeding bird nesting period. 

Views or aesthetics X Bridge over Birch River would be highly visible to local boaters and could not be mitigated as effectively as eastern corridor alternative. 

Or be a pre-condition or 

justification for 

This Project is a stand-alone subset of the on-going Springpole Gold Project. The other aspects of the Springpole Gold Project are not 

X 

implementing another 

included in the scope of this Class EA. 

project 

Adjacent or nearby uses, 

persons or property 

Social, Cultural and Economic Considerations 

Cultural heritage 

resources-including 

archaeological sites, 

X 

built heritage and 

cultural heritage 

landscapes 

Or displace people, 

businesses, institutions 

or public facilities 

Community character, 

enjoyment of property or 

local amenities 

Or increase demands on 

government services or 


Public health and/or 

safety 

X 

X 

X Not applicable. 

X Not applicable. 

X 

Project maintains a reasonably large setback from remote tourism operators and private landowners, similar to setbacks elsewhere in 

the SFL. 

Regionally, this corridor would exert greater cumulative effects because it would duplicate the access corridor of the 2014-2019 FMP. 

Based on desktop analysis by licensed professional archaeologist, there is an increased potential for archaeological values along this 

corridor (refer to Appendix 2). 

Engagement with tourism operators and private landowners is on-going in order to address concerns that arise. As indicated in Table 

3-2, GCU is receptive to good neighbour policy, Resource Stewardship Agreement and participation in a stakeholder working group. 

Increased access to lakes could be a positive effect for private landowners if access is authorized by MNR. This alternative would 

potentially increase unwanted access to Birch Lake, a valued tourist lake, because this alternative comes to within several hundred 

metres of the shoreline. GCU notes that it has engaged local interests as well as regional interests, as indicated in Appendix 3. 

Safety of the public will be somewhat increased because of ability to evacuate areas year-round by a land-based corridor in case of fire, 

or medical emergencies. Consistent with GCU’s track record of being helpful to other parties in the region, access will be arranged by 

GCU personnel for other stakeholders in the area in the event of an emergency situation. 

Local, regional or 

provincial economies or 

businesses 

X Enhanced employment and contracting opportunities, procurement of goods and services, training opportunities. 

July 2013 Page 11





Tourism values X 

Aboriginal Considerations 

Net Effect 

Negative Effect (1) Positive Effect (1) 

Nil Unk 



Remoteness of the area marketability of tourism operators could be negatively impacted. This corridor is through a less developed 

region and would result in a greater cumulative impact for the region because it would duplicate the FMP-approved access corridor in 

the long-term. Increased access to lakes could be a positive effect if there are lodge owners seeking to convert to a drive-in mode of 

operation and access is authorized by MNR. Would potentially increase unwanted access to Birch Lake, a valued tourist lake, because 

this alternative comes to within several hundred metres of the shoreline. A road by GCU would increase access in this area where no 

roads are currently planned by any other interests (i.e. First Nation, forestry company) that are known to GCU. There are more tourism 

operators on Birch Lake who expressed concerns regarding access to Birch Lake compared to Springpole Lake. 

First Nation reserves or 

communities 

X 

Increased employment and training, business, contracting opportunities, as described in Section 3.1. Potentially better emergency 

response capabilities due to improved access. 

Spiritual, ceremonial or 

cultural sites 

Traditional land or 

resources used for 

harvesting, activities 

X None are identified to date in vicinity of this corridor. 

X None are identified to date in vicinity of this corridor. 

Aboriginal values X No such values communicated to GCU to date by the engaged Aboriginal communities. 

Lands subject to land 

claims 

Other (Archaeological 

Sites) 

X 

X None are known. 

Based on desktop analysis by licensed professional archaeologist (no field work), there is an increased potential for archaeological 

values along this corridor (refer to Appendix 2). First Nation technicians participated in each archaeological field program. GCU will 

implement a Chance Find Procedure (refer to Definition of Terms and Acronyms) to further protect archaeological values. 

TOTAL 1 4 15 19 0 0 2 0 

(1) Refer to MNR (2003) for definition of the categories of positive and negative effects. http://www.mnr.gov.on.ca/en/Business/LUEPS/Publication/245473.html 

July 2013 Page 12




2.2.2 Eastern Corridor 

A general description of this alternative, along with the advantages and disadvantages, is provided 

in the bullets below. 

The eastern corridor trends southeast from the area of the Deposit to the outflow of 

Springpole Lake via Birch River and connects with the planned Wenasaga Road that is 

approved in the 2009-2019 FMP and is located within the 2011 burn area (refer to Figure 2- 

1). 

The eastern corridor meets the objective of reliable year-round, land-based access to the 

area of the Deposit. The synergies of the eastern corridor with the currently approved and 

future proposed Wenasaga Road extension are noted, as well as the reduction in the 

potential for cumulative effects in the region compared with other potential corridor 

alignments. For convenience, Figure 2-2 presents the Wenasaga Road approved in the 

2009-2019 FMP and the future proposed expansion to the Wenasaga Road in the Trout 

Lake Forest. 

Based on a Stage 1 Archaeological Assessment by Horizon Archaeology, the eastern 

corridor has a lower potential to host archaeological values compared with the western 

corridor (refer to Appendix 2). 

Based on a holistic effects analysis of the caribou range, this corridor is regarded as having 

a lower potential to negatively affect caribou (DST, 2012). 

If the Springpole Gold Project proceeds to production, progressive mine planning would 

require the site to be situated within one (1) watershed rather than straddling multiple 

watersheds to the extent practical. In the event that a production phase is proposed, this 

corridor lends itself well to a compact mine site within a single watershed that branches off to 

access the various mine site features. Furthermore, in order to minimize the overall 

development footprint on the landscape it would be desirable to have the access corridor 

overlap with the mine site features and this corridor alternative lends itself well to this sort of 

progressive planning. 

An analysis of the effects (positive and negative) associated with this alternative was undertaken in 

accordance with Section 3 of MNR (2003) and is presented in Table 2-2. Unless otherwise stated in 

Table 2-2, this analysis assumes that conventional, proven mitigation measures are applied to the 

alternative in accordance with applicable guidance documents from MNR and DFO that are 

referenced herein. 

July 2013 Page 13





Net Effect 

Negative (1) Nil Unk 

Positive (1) 


Natural Environment Considerations 

Table 2-2: Effects Analysis for Eastern Corridor 


Air quality X 

Water quality or quantity X 

Species at risk or their 

habitat 

X 

Maintain equipment in accordance with manufacturer recommendations. No material impacts associated with the Project (fugitive dust, 

emission from combustion equipment). 

Road development and installation of water crossings and eventual decommissioning would conform to the MNR and DFO guidance 

documents referenced herein, as well as AOC prescriptions in the FMP. Erosion and sediment control plan to be developed and 

followed, as per MNR (1995). Post construction FOIP audit and monitoring post construction is planned, as per Section 8. Beyond the 

FMP Approved Road, this corridor requires seven (7) water crossings, one of which is a clear span bridge over the Birch River (refer to 

Figure 2-1). The FMP Approved Road, which would be constructed by the SFL holder in accordance with the 2009-2019 FMP regardless 

of GCU’s activities, requires seven (7) crossings, including a clear span bridge over Dead Dog Creek. Additional engineering details are 

provided in Appendix 7, beyond the major water crossings locations that are shown on Figure 2-1. 

The access corridor would be a linear development through a caribou range. Based on the Caribou Screening Tool and DST (2012), this 

corridor is regarded as having a lesser impact on the range than the western corridor. Refer to DST (2012) in Appendix 4 for discussion 

of potential impacts to caribou and wolverine. 

Significant earth or life 

science features 


Fish or other aquatic 

species, communities or 

their habitat (including 

movement of resident or 


X 

Through installation of modern, monitored gates, there should be minimal increased public access to lakes, which would increase fishing 

pressure. Road development and installation of water crossings and eventual decommissioning would conform to the MNR and DFO guidance 

documents referenced herein, as well as AOC prescriptions in the FMP. 

Land subject to natural or 

human made hazards 

X 

None identified to date. 

Recovery of a species 

under special 

management program 

X 

The access corridor would be a linear development through a caribou range. Based on the Caribou Screening Tool and DST (2012), this 

corridor is regarded as having a lesser impact on the range. Refer to DST (2012) in Appendix 4 and DST (2013) in Appendix 5 for 

discussion. 

Ecological integrity X 

The access corridor would be a linear development through an area of historic exploration and would largely follow the 2011 burn area 

and area of FMP-approved activities. Refer to DST (2012) for further discussion. 

Terrestrial wildlife 

(including numbers, 

diversity and movement 

of resident or migratory 

species) 

Natural vegetation and 

terrestrial habitat linkages 

or corridors through 

fragmentation, alteration 

and/or critical loss 

X 

X Refer to Section 6.4 for discussion. 

Potential for an increase in road mortalities of a variety of terrestrial wildlife species. This threat has the potential for mitigation and is 

dependent on the intensity of road use. Refer to DST (2012) for further discussion. The eastern corridor stays outside of the red tail hawk 

standard 20m AOC. The road is located within the 100m Critical Breeding AOC (refer to Figure 2-1), as per Table 4.2e of MNR (2010). 

Standards and guidelines for common stick-nesting bird nest sites and unknown stick nests (page 82 and 83) because the road will be 

constructed outside the critical breeding time for red-tailed hawks. 

July 2013 Page 14




Net Effect 


Negative (1) Positive (1) 

Nil Unk 


Permafrost X Not applicable. 

Soils and sediment 

quality 

Drainage or flooding X 

Sedimentation or erosion X 

Release of contaminants 

in soils, sediments 

Natural heritage features 

and areas 


X Road development and installation of water crossings and eventual decommissioning would conform to the MNR and DFO guidance 

documents referenced herein, as well as AOC prescriptions in the FMP. Water crossings and cross-culverts would be to primary road 

standards, cross-drainage culvert locations demarcated in the field by independent road consultant. Erosion and sediment control plan to 

be developed and followed, as per MNR (1995). Post construction FOIP audit and monitoring post construction is planned, as per 

Section 8. 

X 


Other (Potential for 

introduction of invasive 

exotics) 

X 

Measures will be implemented to mitigate this risk (use appropriate seed for re-vegetation that does not include exotic species, use local 

contractors & equipment). 

Land Use, Resource Management Considerations 

Access to trails or 

inaccessible areas (and 

water) 

X 

Public access will be same as in the FMP due to use of modern, monitored gate at the end of the FMP road. Beyond the FMP-road, 

access will be gated and restricted to GCU personnel, Crown employees, their agents and stakeholders with MNR approval to use the 

road (e.g. tourism outfitter, commercial bait fisherman). There are potential positive effects for lodge owners on Birch Lake that may wish 

to convert their businesses to drive-in operations, with access through GCU’s camp (pending GCU and MNR approval). Maintains large 

setback from Birch Lake compared to western corridor alternative because it would be necessary for unwanted users to travel through 

GCU’s monitored camp in order to access Birch Lake. Refer to Figure 2-1 for distances from proposed road to remote tourism lakes. 

Obstruct navigation X Comply with approval from Transport Canada for any approvals to cross a navigable water (Birch River). 

Obstruct other resource 

management projects 

X 

Synergies with the Wenasaga road that is planned by SFL holder. Potential synergies with future all-weather road to Cat Lake First 

Nation. 

Traffic patterns or traffic 


X 

Access will be restricted by modern, monitored gate to limit public access. Road use will be primarily during winter season in order to 

avoid active season for tourism operators, caribou calving window and migratory bird nesting period. 

Recreational importancepublic 

or private 

X 

Public access is to remain the same as the provisions in the FMP, with access beyond the FMP Approved Road being effectively 

restricted through the use of a modern, monitored gate with security camera. This issue has been integrated into GCU’s issues 

management matrix in Table 3-2. Refer to Tables 3-2 and 6-1 for management strategy and mitigation measures. GCU acknowledges that 

the road could be a positive impact to some stakeholders and a negative impact if access were allowed by MNR. 

Or create excessive 

waste materials 

X 

Project would not create excessive waste materials. Waste from the exploration site would continue to be containerized to avoid 

attracting wildlife and shipped off-site for disposal at a MOE approved facility. 

Or commit a significant 

amount of a nonrenewable 

resource (e.g. 

aggregates, agricultural 

land) 

X Minor amount of aggregate from FAPs and GCU’s patented land to be utilized for water crossings associated with road. 

July 2013 Page 15





Noise levels X 

Views or aesthetics X 

Or be a pre-condition or 

justification for 

implementing another 

project 

Adjacent or nearby uses, 

persons or property 

Social, Cultural and Economic Considerations 

Net Effect 


Nil Unk 


X 

X 


Noise impacts will be highest during the construction phase, which is planned during winter months to avoid active period of tourism 

operators, caribou calving window and breeding bird nesting period. 

Bridge over Birch River would be visible to local boaters during extreme high water periods when rapids are navigable. Refer to Section 

6.3 for further discussion regarding this mitigation measure and Photograph 6-1 in Section 6.3. 

This Project is a stand-alone subset of the on-going Springpole Gold Project. The other aspects of the Springpole Gold Project are not 

included in the scope of this Class EA. 

Project maintains a reasonably large setback from remote tourism operators and private landowners, similar to setbacks elsewhere in 

the SFL. 

Cultural heritage 

resources-including 

archaeological sites, built 

heritage and cultural 

heritage landscapes 

Or displace people, 

businesses, institutions 

or public facilities 

Community character, 

enjoyment of property or 

local amenities 

X 

X 

Based on desktop analysis by licensed professional archaeologist, there is a reduced potential for archaeological values along this 

corridor. Extensive field work in 2012 identified archaeological values so that these can be avoided by the access corridor. GCU will 

implement a Chance Find Procedure (refer to Definition of Terms and Acronyms) to further protect archaeological values. 

X Project would not create displacements. 

On-going engagement with tourism operators and private landowners planned. As indicated in Table 3-2, GCU is receptive to good 

neighbour policy, Resource Stewardship Agreement and participation in a stakeholder working group. GCU notes that it has engaged 

local interests as well as regional interests, as indicated in Appendix 3. 

Or increase demands on 

government services or 


Public health and/or 

safety 

Local, regional or 

provincial economies or 

businesses 

X 

X 

Project will reduce the cost for the Wenasaga Road extension by the SFL holder because GCU will install water crossings and road 

base. 

Safety of the public will be somewhat increased because of ability to evacuate areas year-round by a land-based corridor in case of fire, 

or medical emergencies. Consistent with GCU’s track record of being helpful to other parties in the region, access will be arranged by 

GCU personnel for other stakeholders in the area in the event of an emergency situation. 

X Enhanced employment and contracting opportunities, procurement of goods and services, on-the-job training opportunities. 

Tourism values X 

Remoteness of the area marketability of tourism operators could be negatively impacted. This issue has been integrated into GCU’s 

issues management matrix in Table 3-2. Refer to Table 3-2 for management strategy and mitigation measures, as well as Section 6. 

Increased access to lakes could be a positive effect if there are lodge owners seeking to convert to a drive-in mode of operation. 

Unlike the western corridor alternative, the eastern corridor maintains a robust setback from Birch Lake, a valued tourist lake. This 

ranking is assigned with the knowledge that the FMP Approved Road will be built regardless of GCU’s activities. There are more tourism 

operators on Birch Lake who expressed concerns compared to Springpole Lake. 

July 2013 Page 16




Net Effect 

Screening Criteria Negative (1) Positive (1) 


Nil Unk 


Aboriginal Considerations 

First Nation reserves or 

communities 

X 

Increased employment and training, business, contracting opportunities, as described in Section 3.1. Potentially better emergency 

response capabilities due to improved access. 

Spiritual, ceremonial or 

cultural sites 

X 

None are identified to date in vicinity of the road. GCU is committed to on-going consultation and will respond to new information that 

may become available in the future. 

Traditional land or 

resources used for 

harvesting, activities 

Aboriginal values X 

Lands subject to land 

claims 

Other (Archaeological 

Sites) 

X 

X None are known. 

X 

None are identified to date in vicinity of the road. GCU is committed to on-going consultation and will respond to new information that 

may become available in the future. 

No such values communicated to GCU to date by the engaged Aboriginal communities. GCU is committed to on-going consultation and 

will respond to new information that may become available in the future. 

Based on desktop analysis by licensed professional archaeologist, there is a reduced potential for archaeological values along this 

corridor. Extensive field work in 2012 with direct participation of First Nation technicians identified archaeological values so that they 

could be avoided by the access corridor. GCU will implement a Chance Find Procedure (refer to Definition of Terms and Acronyms) to 

further protect archaeological values. 

TOTAL 1 0 15 20 0 2 3 0 

(1) Refer to MNR (2003) for definition of the categories of positive and negative effects. http://www.mnr.gov.on.ca/en/Business/LUEPS/Publication/245473.html 

July 2013 Page 17




2.2.3 Selection of Preferred Alternative 

For the purpose of the effects analysis in Section 2.2, it is assumed that the applicable mitigation 

measures described in the AOC prescriptions of the FMP, as well as the MNR and DFO guidance 

documents referenced herein, are applied. 

Based on the comparative analysis presented in Section 2.2 that is in general accordance with 

Section 3 of MNR (2003), the eastern access corridor has been selected as the preferred alternative 

because it has fewer negative effects, more positive effects and an equivalent number of unknowns. 

The results of the comparative analysis are summarized in Table 2-3 below. 

Table 2-3: Summary of Effects Analysis for Proposed Corridors 

Net Effect 

Alternative 


Corridor 

High Medium Low Nil Unk Low Medium High 

Western 1 4 15 19 0 0 2 0 

Eastern 1 0 15 20 0 2 3 0 

(1) Refer to MNR (2003) for definition of positive and negative effects. 

Furthermore, the eastern corridor has been selected alternative for the reasons listed in the bullets 

below. 

 

 

 

 

 

 

 

 

Approximately 50% of the eastern corridor is already approved in the 2014-2019 FMP and is 

within the 2011 wildfire area. 

Reduced risk of impacts to archaeological values and biological values. 

Fewer water crossings associated with the portion of road beyond the FMP Approved Road 

(7 water crossings beyond the end of the 2014-2019 FMP Approved Road) compared with 

the western corridor (11 crossings for western corridor). 

Potential synergies with future development plans for the region (i.e. future forestry roads 

that are contemplated in the Forest Management Plan). It is recognized that this is a 

potential synergy only and that any road building would require an additional environmental 

assessment and approvals process. 

Potential synergies with an all-weather access road to Cat Lake First Nation (evaluation in 

progress by Cat Lake First Nation). 

Reduced potential for cumulative effects in the region compared with western corridor option 

because the western corridor option would duplicate FMP roads to the east and would 

increase habitat fragmentation on a regional scale. 

If the Springpole Gold Project is economic and a positive production decision is made, the 

surface footprint would necessarily be proposed east of Springpole Lake and along the 

eastern corridor because there is insufficient space available north, west or south of 

Springpole Lake. If the Springpole Gold Project progresses beyond the current definition and 

exploration stage, the eastern corridor would be a preferred alternative from an overall 

development footprint minimization perspective (i.e. the eastern corridor would bisect the 

development footprint of the mine site rather than be a development footprint that is in 

addition to the mine site). 

Fewer negative impacts to caribou calving habitat and wintering areas. Both corridors would 

be located near calving lakes, but the eastern corridor would be located further away from 

sensitive habitat. The western corridor would bisect a wintering area near Okanse Lake if 

July 2013 Page 18




moved away from calving locations. 

The eastern corridor has been carried forward as the preferred alternative corridor that will be 

proposed by GCU in Section 5 of this Report. As further described in Section 5, the proposed 

construction, use and decommissioning of the road has been fundamentally modified to respect the 

interests and values of the engaged communities and stakeholders. 

Mitigation measures will be integrated directly into the Project execution plan to the extent practical 

for ease of implementation by GCU and for enforceability by MNR (refer to Section 5). Additional 

mitigation measures to further mitigate potentially significant residual negative effects are described 

in Section 6.1. 

The construction cost for the eastern corridor is currently being refined in collaboration with potential 

contractors and disclosure of budget pricing is not authorized. However, based on benchmarking of 

costs for similar projects by a Registered Professional Forester, the construction costs for a ~45 km 

winter road (refer to description in Section 5) has been estimated at approximately $1 million (+/-), 

which includes a reasonable allowance for the clear span bridge over the Birch River and Dead Dog 

Creek as well as bedrock excavation on the west abutment. There is no collaboration with any other 

parties on this road and the entire cost would be borne by GCU. As GCU is opting for the more 

costly corridor alternative due to environmental and social reasons, the need for a robust cost 

benefit analysis is regarded as unnecessary. 

Due to the defensible selection of the eastern corridor as the preferred alternative in accordance 

with MNR (2003), in spite of greater cost, and the resultant reduced risk to values in the region, the 

need for a more rigorous comparison of the two (2) alternative corridors has been obviated. 

July 2013 Page 19




3.0 CONSULTATION AND REQUIRED APPROVALS FOR PROJECT 

GCU has engaged in consultation with Aboriginal communities, non-Aboriginal stakeholders and 

government to explain the Project and to understand their respective interests. GCU has adjusted 

its Project in response to that consultation to avoid or mitigate any reasonable concerns identified 

and to align interests where possible. Although the EA process is intended to reach a conclusion 

with respect to consultation on a proposed undertaking, it is GCU`s position that consultation is an 

ongoing process, and as such GCU will continue to work with interested stakeholders and identified 

Aboriginal Communities during the life of the Project to share information on the Project and 

respond to concerns. This document describes the on-going consultation process that has been 

undertaken to date, which is regarded as sufficiently advanced to identify the concerns associated 

with an undertaking such as the proposed Project. 

3.1 Aboriginal Communities 

GCU has engaged in consultation with Aboriginal communities with established or asserted 

Aboriginal and Treaty rights in the Project area, under the guidance and direction of the Ontario 

government. GCU is committed to continue meaningful engagement with the Aboriginal 

communities beyond the conclusion of this EA. 

In addition to the extensive work that GCU undertook to identify and mitigate project impacts 

generally, GCU also consulted in good-faith with Aboriginal communities on the Project to identify 

specific aboriginal interests. The discussion that follows summarizes the efforts to consult the 

Aboriginal communities that have been identified by the Ontario government. 

3.1.1 Cat Lake, Slate Falls and Lac Seul First Nations (The Protocol Nations) 

GCU has engaged in consultation with the First Nations of Cat Lake, Slate Falls, and Lac Seul, who 

were identified to GCU by the Crown in 2009 as the affected First Nations with respect to the 

Springpole Gold Project site. 

On 22 May 2012, Chiefs from the First Nation communities of Cat Lake, Slate Falls and Lac Seul 

signed an internal protocol agreement, in which they agreed to work together for the purpose of 

negotiations with GCU. 

A Working Committee, with members from each of the Protocol Nations, meets on a regular basis to 

discuss the progress of the Springpole Gold Project and the development of an agreement between 

GCU and the Protocol Nations that would allow the Springpole Gold Project to be developed with 

the support of the Protocol Nations, while respecting their Aboriginal and Treaty Rights. GCU is 

engaged in ongoing discussions with this Working Committee. 

Although there had been previous discussion about the possibility of an access road to the 

Springpole Gold Project in 2011, the current access corridor proposal was first presented to the 

working group on 10 February 2012. 

A map of the proposed access alternatives was informally presented to interested First Nation 

representatives after a formal meeting in Thunder Bay, and a copy was given to each of the Chiefs, 

and to the Working Committee Chair for further deliberation and future discussion. GCU requested 

an opportunity to present the proposal to the Working Committee in a more formal setting at an 

July 2013 Page 20




internal meeting held in Sioux Lookout on 21 March 2012, but the offer was declined. GCU has 

been informed that the Working Committee reviewed the Project map at that meeting. 

On 7 April 2012, GCU sent the corridor alternatives map to members of the Working Committee and 

community leaders by e-mail. GCU once again requested feedback and offered to discuss the 

proposed undertaking with the Working Committee and community leaders. 

A formal presentation of the proposed Project was delivered to the Working Committee as part of a 

Springpole Gold Project update presentation at a meeting conducted on 4 May 2012. This 

presentation reviewed the justification for the road, the alternatives assessed, preliminary Project 

schedule and the environmental management practices associated with the Project. GCU provided 

a copy of the presentation as a handout for further study. 

At the 25 May 2012 working group meeting, GCU offered to conduct Open Houses in each Protocol 

Nation’s community to allow community members to pre-screen the project description before it was 

submitted to the MNR, but the offer was declined. After the meeting, GCU provided a briefing on the 

road proposal and related baseline studies to a Cat Lake First Nation Councillor, who was standing 

in for absent working group members from his community. The Councillor expressed gratitude for 

the update and indicated that Cat Lake has an interest in the outcome of the road, because it may 

affect their plans for a future all-weather road to the community. 

On 21 July 2012, GCU released a report entitled Springpole Exploration and Access Corridor 

Project, Base Case Project Description Report, which was circulated to the Aboriginal communities 

and affected stakeholders in the area. Still part of the pre-screening process, the purpose of this 

document was to allow the MNR to determine the category of the environmental assessment 

required pursuant to MNR (2003), to solicit feedback from the aforementioned groups, and to 

identify potential concerns and develop mitigation measures. Copies of this document were 

circulated to all three Protocol Nation communities and additional copies were provided to working 

group members after the 27 July 2012 meeting in Red Lake. No official comments have been 

received on this proposal, despite GCU’s many attempts to solicit comments from the Protocol 

Nations in this pre-consultation phase for the ESR. 

On 17 October 2012, GCU released the Draft ESR and notified the Protocol Nations by email and 

regular mail. GCU also posted notifications in three (3) local newspapers, including the October 17 th 

editions of the Northern Sun News (Red Lake) and the Bulletin (Sioux Lookout), and the October 

18 th edition of the Wawatay News (Sioux Lookout). Follow-up calls were made to representatives 

from each community to confirm receipt of the notices, ensure that the document could be accessed 

from GCU’s website for review and offer to conduct Open House sessions in each community to 

review the proposal. The MNR also sent notifications to each of the Protocol Nations on 17 October 

2012, confirming it had received the Draft ESR document and offering to facilitate consultation on 

the Project. 

Between the release of the Draft ESR and the finalization of this document, both GCU and the MNR 

made many requests to present the proposal to the community and to solicit feedback on the 

proposal. The requests were declined. 

July 2013 Page 21




On 23 November 2012, Cat Lake First Nation sent a letter to the MNR stating that they were still in 

the process of reviewing the Draft ESR and not prepared to comment, but they were very concerned 

that GCU was going ahead with the project and over-riding their process and community concerns. 

They indicated that their response to the ESR would be forthcoming. 

On 6 December 2012, GCU received a letter from Cat Lake First Nation, copied to the Ministers of 

Natural Resources, Northern Development and Mines, Environment, and Transportation, as well as 

the Grand Chief of the Nishnawbe Aski Nation, Windigo Tribal Council, Slate Falls and Lac Seul. 

The letter stated that it was in response to the Draft ESR and the Springpole Gold Project in its 

entirety. However, the letter did not offer any comment on the proposed Project. 

Since December 2012, GCU has continued its efforts to seek meaningful consultation with the 

Protocol Nations on the Project and also the negotiation of an exploration accommodation 

agreement. GCU has also offered capacity funding to assist the Protocol First Nations in the 

consultation process. 

On 9 April 2013, the MNR convened a meeting in Slate Falls with participants from the Protocol 

Nations to discuss the consultation process to date. At this meeting it was agreed that MNR and 

GCU would be allowed to conduct joint open house style information sessions discussing the road 

proposal in each of the three (3) communities of Cat Lake, Slate Falls and Lac Seul First Nations. It 

was also agreed that a meeting would be convened between the Chiefs of all three (3) communities, 

the MNR and GCU when the open houses were concluded, to report back to the Chiefs regarding 

the comments received and any additional mitigation measures implemented by GCU to address 

these concerns, and to receive any additional comments from the Chiefs on the proposed Project. 

The open houses were conducted in Slate Falls on 27 May 2013, in Cat Lake on 28 May 2013 and 

in Lac Seul First Nation on 11 June 2013. Attendance was generally good at these open houses 

with attendances in the order of 15-25 adults, and an additional 15-30 students in Slate Falls and 

Cat Lake. The information sessions were structured primarily as poster sessions, with MNR and 

GCU personnel offering one-on-one discussion of the proposal with interested parties. Road 

proposal and project update presentations were also provided in Slate Falls and Cat Lake, where 

the information session participants indicated they were interested in a more formal presentation. 

Comments were documented from the open houses and reviewed by GCU to develop additional 

mitigation measures. 

Upon request, a meeting was convened on 12 June 2013 with one of the trapline holders who could 

not attend the open house sessions, to review the proposed Project and the exploration activities at 

the Property. The trapline holder indicated that he had no concerns with the proposed access 

corridor and indicated that he thought a road in that area would be good. After explaining that GCU 

would not be able to allow anyone to use the road to access the area until it becomes a public 

access forestry road, the trapline holder indicated he would still like a road there. 

A meeting between the Protocol Nation Chiefs, MNR and GCU was convened on 8 July 2013 in Red 

Lake to review the feedback from the open houses and further discuss the on-going consultation 

process for the Project. 

July 2013 Page 22




Section 3.1.4 describes the involvement of the Protocol Nations in the archaeological and biological 

assessment work conducted to date. This Section also describes the efforts regarding the 

dissemination of information to the communities and collection of traditional knowledge in relation to 

the Springpole Gold Project. 

GCU believes it has taken all reasonable steps in good faith to consult with the Protocol First Nation 

regarding the Project. Concerns identified during these open houses have been generally reflected 

in Table 3-1 and in detail in Appendix 8. GCU has assessed the Project and designed it in 

accordance with good practice to avoid or minimize environmental and social impacts in the region 

and on the Protocol Nations’ Aboriginal and Treaty rights. 

3.1.2 Wabauskang First Nation 

A letter of introduction and a map showing the two proposed road alternatives was sent by email to 

Wabauskang First Nation (“WFN”) on 9 May 2012, extending an invitation to meet with the Chief 

and his representatives to discuss the project. GCU received verbal confirmation that the 

introductory documents were received, but a meeting was not scheduled at that time. 

On 21 July 2012, a copy of the Base Case Project Description Report was mailed to WFN as part of 

the pre-screening consultation efforts for the road proposal. Contact with WFN was established to 

confirm that the Base Case Project Description had been received. No comments were offered on 

the proposal at that time. 

An introductory meeting was held between representatives from WFN, Bimose Tribal Council and 

GCU on 4 October 2012. GCU presented background information on the company and the 

proposed (access corridor) Project, which it understood to be partly within Treaty 3 area and within 

WFN’s area of interest, based on information provided by the Crown. GCU asked the 

representatives from WFN and Bimose Tribal Council to present the Project information to the Chief 

and Council and to provide comments to GCU. 

On 28 November 2012, GCU scheduled a meeting and Open House session in WFN. At the 

meeting, WFN expressed concern that GCU had been in discussions with other First Nations for a 

long time before WFN was contacted by GCU. 

GCU explained that consultation was being undertaken under the direction of the Crown. WFN was 

not identified by the Crown as having rights in the Springpole Gold Project area. GCU also explained 

that before April 2012, the consultation that had been undertaken with the other First Nation 

communities was primarily about the work at the Springpole Gold Project site. When GCU proposed 

construction of the road, the Crown advised GCU to discuss the road with WFN, because part of the 

road crossed through Treaty 3, where WFN holds Aboriginal and Treaty rights. WFN advised GCU 

that they were still working to define the boundary of their Traditional Lands and would update GCU 

when more information was available. No WFN members attended the afternoon Open House 

session, so GCU left a copy of the Project maps and the road proposal presentation in the 

community for further review by interested parties. 

On 13 December 2012, GCU received a letter from WFN asserting that the proposed Springpole 

Gold Project is in WFN Traditional Territory and that WFN’s Aboriginal and Treaty Rights will be 

impacted. A budget for an independent environmental review of the Access Corridor Project was 

July 2013 Page 23




provided and WFN stated that at this time they do not support the Project. WFN also expressed 

concern that they were not invited to participate in the archaeological or biological assessment work 

that was conducted on the Project. 

Since December 2012, WFN, MNR and GCU have continued efforts to develop a work plan to fulfill 

WFN’s consultation and accommodation protocol requirements. GCU is willing to provide 

reasonable support for WFN’s on-going traditional use study to identify any sensitive sites that 

should be avoided by the proposed road. In GCU’s view, the environmental protection measures 

proposed for the Project are proven through many years of experience and effective to mitigate any 

potential impacts. Thus, further environmental review of the Project is not warranted. 

On 16 April 2013, a meeting was conducted in WFN between WFN, MNR, MNDM and GCU to 

review the proposed Project. WFN presented a proposal to have an independent consultant conduct 

a Traditional Use Study of the road corridor and surrounding area to allow WFN to determine 

whether the road will impact their Aboriginal and Treaty Rights. WFN requested that the MNR, 

MNDM and GCU jointly fund the proposal to complete the Traditional Use Study and these 

discussions are part of the on-going consultation process. 

GCU considers the risk of a sensitive site being identified on the eastern corridor through the 

Aboriginal Traditional Use Study to be effectively mitigated to the extent practical for the reasons 

listed below. 

1. The eastern corridor was subjected to an archaeological study during this EA, conducted by 

a licensed professional archaeologist who completed State 1 through Stage 3 studies as 

needed along the corridor, all in accordance with prescriptive standards and guidelines for 

consultant archaeologists from the Ministry of Tourism and Culture. 

2. There was input by the other First Nation communities having local knowledge of the area 

on the archaeological and biological assessment studies in the area. 

3. The FMP Approved Road portion of eastern corridor was previously screened for the 2009- 

2019 Trout Lake FMP, which resulted in approval of the same corridor for construction of a 

primary forestry access road. 

Even with a low risk, GCU would proceed with caution. If a sensitive site is identified by a traditional 

use study, GCU will work with WFN to avoid or mitigate any impacts before construction 

commences. In addition, GCU will follow the Chance Find Procedure defined herein (refer to 

Definition of Terms and Acronyms). 

GCU believes the Project may be approved now without risk to WFN interests for the following 

reasons: 

 

 

 

 

WFN has not identified any specific concerns about the Project; 

the risk of a sensitive site being undetected and adversely affected by the Project is low; 

the Project impacts have been well studied and representatives from the Protocol First 

Nations participated in the archaeological assessment of the eastern corridor; 

the mitigation measures outlined herein are well proven and will minimize the Project 

impacts; and 

July 2013 Page 24




 

WFN will have reasonable time and funding to complete its traditional use study before 

construction commences. GCU will contribute reasonable funding towards the study and will 

review the results with WFN with a view to adjusting the Project as reasonable and 

necessary to avoid any harm to newly identified sensitive sites. In addition, GCU will follow 

the Chance Find Procedure defined herein (refer to Definition of Terms and Acronyms). 

3.1.3 Métis Nation of Ontario 

GCU met with a representative of the Métis Nation of Ontario (“MNO”) in Thunder Bay on 5 April 

2012. Background information was exchanged between GCU and the MNO, with GCU providing 

information about the Springpole Gold Project and the MNO providing information about their history 

and consultation process. GCU was advised to send a project notification for the Springpole Gold 

Project to the Lands and Resources Branch of the MNO in Ottawa, and an introductory meeting 

would be scheduled. GCU sent its project notification to the Ottawa branch on 14 May 2012. 

On 21 July 2012 two (2) copies of the Base Case Project Description Report were mailed to the 

MNO: one to the Thunder Bay office and one to the Dryden Office. After several attempts to reach 

contacts at the northwest MNO (Region One Council) to discuss the Base Case Project Description 

Report, GCU established contact in late August. 

An introductory meeting with three (3) consultation committee representatives was held in Kenora on 

10 October 2012. The consultation committee made a presentation on the history and structure of 

the MNO organization and the consultation process. GCU presented background information on the 

company and the proposed access corridor project which is currently in the permitting process. 

GCU provided a digital copy of the presentation to the consultation committee representatives to 

share with the rest of the committee at their next meeting. 

On 18 November 2012, a consultation meeting was convened in Toronto, to coincide with the 

Canadian Aboriginal Minerals Association Conference, which allowed all of the Representatives 

from Region One Council to attend. The Draft ESR proposal was reviewed in detail at this meeting. 

On 13 December 2012, the MNO provided a letter to GCU stating that the MNO had reviewed the 

Draft ESR and are in agreement with the road, provided that there is continued dialogue on the road 

and all future Springpole Gold Project developments. 

On 6 February 2013, GCU held a consultation meeting with the MNO in Kenora. During this 

meeting, GCU provided an update on the status of the road permitting, current activities at the 

Springpole Gold Project site and a review of the exploration plans for 2013 - 2015. 

GCU remains committed to meaningful, on-going and good-faith consultation with MNO. 

3.1.4 Protection of Aboriginal Values and Sensitive Sites 

The identification and protection of Aboriginal values and sensitive sites has been a priority for GCU. 

In addition to maintaining an open-door policy and providing regular notice and updates regarding its 

activities, GCU has also completed extensive, collaborative archaeological and biological values 

assessment work in 2012. 

Archaeological Assessment Work 

July 2013 Page 25




 

 

 

 

 

GCU hired technicians from Cat Lake, Slate Falls and Lac Seul First Nations to 

participate alongside the licensed professional archaeologists from Horizon to complete 

the archaeological assessment of the eastern corridor and general area north of 

Springpole Lake. 

Dr. David Slattery from Horizon Archaeology conducted Open House information sessions in 

the Protocol Nation communities in May to solicit feedback on Traditional Knowledge for the 

archaeological survey. 

In the Stage 1 assessment one technician participated in the visual documentation of 

most of the study area. 

In Stages 2 and 3, the technicians were involved in a hands-on assessment of the 

locations identified as having archaeological potential, and were responsible for finding a 

significant portion of the artifacts discovered. These technicians served as liaisons to 

their communities and participated in the Open House information session conducted in 

Cat Lake First Nation in June. 

Archaeologically significant sites were identified in the vicinity of the Birch River crossing 

and also south of Dole Lake. These findings were presented by Dr. David Slattery of 

Horizon via open-house style information sessions to the communities of Cat Lake First 

Nation on 27 June 2012 and to Slate Falls and Lac Seul First Nations on 30 July 2012. 

On 7 August 2012, the Chiefs of the Protocol Nations consented to the Stage 3 

archaeological assessment work for both of these archaeological sites. Horizon 

completed the Stage 3 work for both of these sites with support from the Aboriginal 

technicians. 

 

 

After the Stage 3 assessment was completed, to better define the spatial extent of these 

archaeological sites, GCU then modified the access corridor to avoid these sensitive 

sites. 

GCU has developed a working draft Chance Find Procedure and has integrated it into 

the site-specific orientation that all site personnel receive prior to commencing work. 

Biological Assessment Work 

GCU hired technicians from Cat Lake and Slate Falls First Nations to assist DST with 

aquatic and terrestrial assessment work along the eastern corridor and general area 

associated with Springpole Lake. The field work focussed on assessing the potential use 

of the area by sturgeon and caribou. At least one (1) technician participated in all field 

programs, with the exception of minnow trapping that was conducted between July 6 and 

July 12. Report findings are presented in DST (2012). 

Mr. Terry Honsberger of DST presented the findings of the studies and sturgeon 

assessment plans at the May in concert with the presentations by Horizon. At these 

meetings, comments were solicited from meeting participants regarding the traditional 

knowledge of sturgeon in Springpole Lake. While some feedback was provided at these 

meetings, no participants suggested that sturgeon have been harvested or observed in 

Springpole Lake. One participant noted that he thought there were sturgeon in the Birch 

River where it enters Springpole Lake (Springpole Arm) although he hadn’t caught any 

there himself. 

Consistent with the request from First Nation communities, biological assessment reports 

will not be issued as final until they are discussed with the First Nation communities. 

3.1.5 Skills Transfer and Capacity Building Initiatives 

To be consistent with the current Mining Act modernization objective related to skills transfer, GCU 

has integrated skills transfer and capacity building initiatives into the Springpole Gold Project. GCU 

has had significant successes involving businesses and individuals from local Aboriginal 

July 2013 Page 26




communities with the Project. The initiatives summarized in the bullets below are particularly 

relevant to the proposed Project. 

 

 

 

 

In 2011, GCU contributed to funding for an Aboriginal Traditional Knowledge study of the 

Springpole Project site, which was conducted through the Cat Lake First Nation – Slate 

Falls First Nation Land Use Planning study. Other contributors to the Traditional 

Knowledge study were the Ontario Ministry of Natural Resources and the Ministry of 

Aboriginal Affairs. 

Technicians from the Protocol Nations’ communities were employed on the 

archaeological and biological assessment campaigns in 2011-2012, as well as routine 

water sampling by GCU. 

GCU has provided training and employment to First Nation members on the on-going 

drilling and other preliminary exploration activities (e.g. geophysics, linecutting, core 

technician duties, etc.) at the Springpole Gold Project. 

GCU is currently in discussions with First Nation joint-venture companies and First 

Nation based businesses to carry out the Project. 

3.1.6 Measures to Protect Aboriginal and Treaty Rights 

Although the ESR process is designed to reach a conclusion with respect to consultation on a 

proposed project, GCU’s position is that consultation with Aboriginal communities is an ongoing 

process. GCU will continue to work with potentially affected Aboriginal communities in respect of the 

Project to openly share information, provide opportunities for dialogue, accept comments, identify 

concerns and undertake appropriate mitigation measures, as appropriate throughout the life of the 

Project. 

GCU has incorporated proven mitigation measures into the Project. Table 3-1 is a matrix that 

summarizes the mitigation measures and implementation strategies that GCU proposes to deal with 

potential concerns or infringements on Aboriginal and Treaty rights. The matrix will be updated as 

additional comments are received from the First Nations and Métis Nation of Ontario. 

July 2013 Page 27




Table 3-1: Summary of Comments and Concerns from Aboriginal Communities 

Comment or Concern Mitigation Measure Implementation Strategy 

Impaired water quality, 

sedimentation and 

effects on fish habitat 

Impacts to migratory 

birds 

Impacts to ungulates 

and furbearers 

Ability to angle, hunt, 

trap and carry out 

subsistence activities. 

Protection of sensitive 

sites 

Notification to First 

Nations of spills. 

Protection of Species 

at Risk 

Adhere to MNR (1995), MNR (1996), MNR (2010), DFO 

(1998), DFO Operational Statement for Span Bridges and 

applicable Area of Concern prescriptions in the Trout Lake 

Forest FMP. 

Harvest timber in winter months when birds are not present 

and breeding will not be affected (~October 30 to April 30, 

pending weather conditions) 

Minimize cumulative impacts to terrestrial development 

footprint in the region by developing the eastern corridor 

and preventing increased access beyond what is provided 

in the current and future FMPs. 

Support specific silvicultural practices in the SFL under 

direction of MNR. Implement silvicultural practices that are 

consistent with FMP for any decommissioning activities 

undertaken by GCU. 

Avoid increased competition for these resources by 

preventing increased access beyond what is provided in 

the current and future FMPs. 

Engage First Nation technicians to participate in 

archaeological and biological values assessment work; 

held open-houses in 2012 to review the Springpole Gold 

Project and discuss values assessment work; hire First 

Nation personnel to the extent practical to help carry out 

field programs; integrate the “no-go” areas and the working 

draft Chance Find Procedure into the site-specific 

orientation for all personnel. 

Adhere to GCU’s Spill Emergency Plan 

Moved road away from sensitive habitats. Road use and 

timing restrictions being discussed with MNR. 

Integrate these requirements into the Project execution 

plan and conditions of the subsequent approvals. 

Engage qualified personnel and supervisors to carry out 

the Project. 

Complete a compliance audit by a Registered 

Professional Forester upon completion of the timber 

harvesting and access corridor construction. 

Regularly monitor and maintain the corridor water 

crossings. 

Install a monitored gate at the end of the FMP-approved 

road, in accordance with a Land Use Permit from MNR. 

Values assessments are materially completed. 

Maintain an open-door policy to receive feedback on an 

on-going basis. 

Conform to Mining Act modernization objective of 

involving Aboriginal community members with the Project 

to the extent practical. 

Spill reporting procedure includes notification to Band 

Offices. 

Adhere to Overall Benefits permit conditions (refer to 

Section 3.4). 

July 2013 Page 28




GCU is committed to continuing to work under the guidance of the Crown to continue meaningful, 

good faith consultation with the Aboriginal communities that may be affected by the Project. 

3.2 Public Stakeholders 

GCU originally approached Domtar in late 2009 to discuss a possible partnership to construct an allweather 

access road to the Springpole Gold Project site. At that time, Domtar was not actively 

working that area and was not interested in pursuing this collaboration. 

3.2.1 Pre-2012 Consultation 

The idea of a road partnership between Domtar and GCU was revisited in March 2011. At that time, 

Domtar was in a better position to move forward and expressed interested in working with GCU on a 

proposal to accelerate the construction of their FMP-approved extension of the Wenasaga Road to 

the southeast outlet of Springpole Lake (Birch River) by autumn of 2011. The MNR requested a 

project description for the road proposal and that the companies engage in consultation with the 

affected stakeholders. As a result, GCU and Domtar contacted many stakeholders to discuss the 

proposal. Some of the tourist operators voiced concerns about the proposed road alignment, visual 

effect of a road on the wilderness experience, noise levels during construction and access to 

previously-inaccessible lakes for fishermen. One operator in particular was strongly opposed to a 

crossing on the rapids between Springpole and Gull lakes. 

GCU and Domtar attended Red Lake Local Citizens’ Committee (“LCC”) meetings on 2 May 2011 

and 6 June 2011 and jointly presented a proposal to accelerate Domtar’s Wenasaga Road 

extension to Springpole Lake during the summer of 2011. An introductory presentation was made on 

2 May 2011 to the LCC members only. A large number of local tourism operators and other 

stakeholders were present at the 6 June 2011 meeting, where a presentation on the current status 

of the project, future plans, and the considered alternate access routes was presented for 

discussion. 

The LCC’s role was to make a recommendation to the MNR whether the requested amendment to 

the Trout Lake Forest FMP should be considered a minor amendment (30 day review process) or a 

major amendment (90 day consultation period). The LCC requested that GCU and Domtar acquire 

letters of support from affected First Nations and other stakeholders in support of a recommendation 

of a minor amendment. Domtar and GCU began consulting the stakeholders and First Nations on 

the proposal; however, further consultation was abandoned when large scale forest fires in the road 

construction area during the summer of 2011 precluded moving ahead with the accelerated 2011 

construction plan. 

3.2.2 Project Consultation 

GCU has conducted outreach and consultation that surpasses the requirements of MNR (2003) for 

a Category C environmental assessment, as described in this section. 

On 5 March 2012, GCU attended the LCC meeting to deliver an update on the Springpole Gold 

Project and explain why the accelerated road construction proposal was not pursued in the summer 

of 2011. GCU has further engaged the LCC and several outfitters in Q1/Q2 2012 regarding the ongoing 

resource definition work, the need for improved access. and the proposed Project. This has 

been the start of GCU’s efforts to actively engage affected stakeholders in the Project area to prescreen 

the proposed Project and identify concerns so appropriate mitigation measures may be 

July 2013 Page 29




developed. Additional details regarding GCU’s consultation activities are summarized in the bullets 

below. 

Consultation for this specific proposal has been on-going since 7 April 2012, utilizing various 

consultation methods, including distribution of digital and/or hard copy project reports via 

email and conventional mail, phone-based consultations, one-on-one meetings, and 

presentations to landowners, businesses and other local stakeholder organizations, upon 

request. 

GCU initiated early pre-screening consultation with sixteen stakeholders who were identified 

by the MNR as potentially having a strong interest in the project. An introductory letter and 

maps showing two (2) corridor alternatives were distributed to the group for comment on 7 

April 2012. All comments received as part of the pre-screening process were documented 

on Stakeholder Contact Forms and summarized in a Public Consultation Summary Log. 

GCU followed up on all comments with one-on-one meetings or email or phone 

consultations, as appropriate in each case. 

On 21 July 2012, GCU released a report entitled Springpole Exploration and Access 

Corridor Project, Base Case Project Description Report, which was circulated via email to all 

Aboriginal communities who were identified by the Crown as exercising rights in the area 

and an expanded list of stakeholders, including government agencies, NGO’s and regional 

stakeholder organizations. The purpose of this document was to allow the MNR to determine 

the category of the environmental assessment required pursuant to MNR (2003) and to 

solicit feedback from the aforementioned groups so GCU could develop mitigation measures 

for any concerns. The list of comments at this stage of the process ranged from “no interest 

in the project” to formal position papers regarding the impact the road will have on specific 

local stakeholders. GCU responded to all expressions of concern, and made several 

modifications to the proposed Project which were reflected in the draft and Final ESRs in 

order mitigate concerns and potential impacts. 

On 17 October 2012, GCU submitted a draft ESR for the proposed Project to the MNR and 

sent out notification to all stakeholders, using a combination of mailings, e-mailings, and 

postings in three (3) local newspapers, including the October 17 th editions of the Northern 

Sun News (Red Lake) and the Bulletin (Sioux Lookout), and in the October 18 th edition of the 

Wawatay News (Sioux Lookout). GCU confirmed receipt of the Notification letters through 

Canada Post tracking system. Additionally, all stakeholders were contacted by phone to 

confirm receipt of the Notification, to ensure the Report could accessed by the stakeholders, 

and to invite further comment and discussion of the proposal. GCU also provided hard 

copies of the Draft ESR to stakeholders upon request. 

GCU made special efforts to contact stakeholders who had expressed concerns with the 

project in the pre-consultation discussions. Several stakeholders did reiterate their concerns 

from the original pre-consultation discussions. In these cases, the mitigation measures that 

were incorporated in the Draft ESR were reviewed in detail, and the stakeholders were 

invited to contact the MNR to further discuss their concerns if they felt the mitigation 

measures did not adequately address the potential impacts. Very few new impacts were 

identified because the pre-consultation with stakeholders had identified most of the potential 

impacts and areas of concern to the stakeholders, and because these items were addressed 

in the Draft ESR All comments were documented and mitigation measures were reevaluated 

by the GCU team, in consultation with the MNR and the stakeholders themselves, 

to identify areas where improvements could be made to better address on-going concerns. 

These improved mitigation measures are all incorporated into this Report. 

July 2013 Page 30




 

 

 

 

GCU received supportive comments for the Project from the following stakeholders: 

o the Municipality of Red Lake 

o the Township of Ear Falls 

o the Northwestern Ontario Prospectors’ Association 

o three (3) Trappers’ organizations 

o two (2) tourist operators 

o three (3) bait fishery owners 

o two (2) businesses in other industries, and 

o three (3) provincial Ministries. 

Table 3-3 summarizes the comments that GCU has received in support of the Project. 

Some tourist operators have accepted GCU’s good-faith offer to meet with the Crownrecommended 

mediator (refer to Section 6.2) to confidentially discuss the Project impacts, 

mitigation measures, and assess any accommodation measures that are required based on 

unmitigated impacts. While these discussions are on-going, conclusion to these discussions 

is not regarded as condition precedent to concluding this EA process. 

A self-identified stakeholder group called the Trout Forest Tourism Operators (“TFTO”) have 

retained legal counsel to help them engage with GCU regarding the Project. While these 

discussions are on-going, conclusion to these discussions is not regarded as condition 

precedent to concluding this EA process. The Final ESR that was published in February 

2013 resulted in the receipt of written comments from the TFTO. The submission by the 

TFTO and GCU’s response to this submission are included in Appendix 9. 

GCU remains committed to continuing the consultation process with the relevant stakeholders in the 

region, as identified by the provincial government and by GCU. The current stakeholder list is 

provided in Appendix 3. GCU has engaged these stakeholders in order to seek feedback and 

identify mitigation measures for any potentially negative impacts associated with the Project, in 

accordance with the consultation requirements outlined in MNR (2003). Due to the extensive 

outreach regarding this Project and by surpassing the requirements from precedents for equivalent 

winter roads in the province, GCU regards the proposed Project as a reasonable approach to a 

simple undertaking that respects the interests of the involved stakeholders. Furthermore, GCU 

regards the consultation to date as sufficient, as it has allowed GCU to reasonably and adequately 

address the interests of the stakeholders affected by the Project. 

Table 3-2 is a matrix that identifies the major concerns expressed by stakeholders along with GCU’s 

view and proposed mitigation measures. The matrix will be updated on an ongoing basis if new 

concerns are identified. 

Table 3-3 summarizes the supportive comments that GCU has received regarding the Project. 

July 2013 Page 31




Table 3-2: Issues Management Matrix 

Summary of Issue GCU View and Mitigation Measure(s) Status (1) / Implementation Strategy 

1. GCU needs a good 

neighbour policy 

2. Impacts on business and 

personal lives of outfitters and 

their employees due to loss of 

remoteness value 

3. Environmental degradation 

and water quality. 

4. Right of way width 

5. Avoid creating new access 

to remote lakes 

GCU is receptive to this and is willing to enter into a Resource Stewardship Agreement that is in general accordance with 

recent precedents. GCU is hopeful that the Springpole Gold Project is economic and that GCU's presence in the area will 

be a lasting one, so GCU is interested in formalizing the practices that are necessary to be regarded as a good neighbour. 

Stakeholder complaints regarding activities on the Project are a very important performance indicator to GCU and GCU's 

target is zero public complaints. 

GCU acknowledges that proximal tourism operators in the region may be affected by the Project due to the further loss of 

remoteness values. GCU also recognizes that there may be a reduced marketability of these businesses due to the ongoing 

forestry operations and ancillary aggregate resource extraction in the area, the 2011 wildfire (refer to Figure 2-1) 

mineral exploration activities by other companies, more distant hydropower developments to the south and the on-going 

practice of traditional subsistence activities by members of rights-bearing Aboriginal communities and related trail 

development. To minimize construction related impacts (noise, dust), GCU proposes to construct during winter months 

when outfitters are not active. Furthermore, GCU intends to primarily use the road during winter months (refer to Section 

5.3). 

The proposed project consists of timber harvesting and corridor construction with water crossings. This is routine work that 

has been conducted in Ontario for decades and the environmental protection measures are well-proven and established. 

GCU shall adhere to the best practice guidance documents referenced herein. GCU has adequate staff to ensure these 

prescriptive environmental protection requirements will be followed during project execution. As well, GCU has committed to 

having the Project overseen by a Registered Professional Forester (“RPF”) and a compliance audit by a RPF following 

construction. 

GCU intends to minimize the ROW width to the extent practical. The corridor that would be harvested would be on the order 

of 10 to 15 m width. 

No increased public access to the region and its lakes are proposed as part of this Project. Pending agreement of MNR, 

GCU proposes to install a modern, monitored gate at the end of the current FMP road in 2013 when the road is constructed. 

No “exclosure”-related impacts to wildlife are anticipated as a result of the gate. When Domtar builds the Wenasaga Road 

extension that is approved in the 2014-2019 FMP, GCU proposes to move the gate to the end of the FMP-approved road, 

which is ~1km south of the Birch River crossing (refer to Figure 2-1 and 2-2). With respect to road building by Domtar, this 

work will involve an upgrade to the road that is built by GCU and not a re-build. In collaboration with MNR and pursuant to 

the Public Lands Act, GCU proposes to post the additional lakes that may not be accessed on the existing sign at the 

Tarpley / Wenasaga Road junction. Furthermore, GCU will place boulders adjacent to the road to prevent boats being 

launched at Birch River. 

6. Noise from road building Construct the road and timber harvesting during the off-season, when the outfitters are not active. 

7. Traffic volume & timing 

8. Opportunities for working 

together 

9. Viewscape at Birch River 

crossing 

Perform bulk, seasonal shipment of consumables during off-season (i.e. perform shipments between late August and early 

June) and minimize road usage during the traditional busy time of late May to mid-July. Notify outfitters of traffic schedule in 

advance so they can plan their activities accordingly. Continue to engage proximal tourism operators in case this sensitive 

timeframe changes. This is regarded as consistent with precedents in recent FMPs. By constructing the road to a winter 

road operational standard, there is a natural incentive for GCU to utilize the road during winter months to the maximum 

extent practical and minimize road use during summer months. Refer to Section 5.3 regarding proposed use of the road. 

GCU is very receptive to this sort of exploratory discussion. GCU is interested in exploring a variety of win-win scenarios. 

GCU is also interested in discussing how road access could be a benefit to tourism operators and landowners during the 

current and future potential phases of the Project. 

GCU is willing to negotiate and adopt a good neighbour policy. GCU does 

not regard this good faith commitment as a condition precedent to 

conclude the Class EA process. GCU wishes to explore the establishment 

of a stakeholder working group with Terms of Reference that are similar to 

those of a Local Citizen’s Committee for a SFL. 

GCU is willing to engage an independent professional recommended by 

the Ontario Government (Mining Lands Commissioner) to serve as an 

arbitrator to facilitate the government's dispute resolution process and 

abide by the recommendations that arise from the process (refer to 

Section 6.2). 

Adhere to the well-proven and established MNR and DFO guidance 

documents described herein. These have been integrated into the project 

execution plan in Section 5. 

Width is consistent with precedents and has been minimized to the extent 

practical, without unnecessarily compromising safety of the road due to 

limited visibility. 

These mitigation measures are regarded as superior to the mitigation 

measures on similar project precedents. The setbacks of the proposed 

corridor from remote tourism lakes are shown on Figure 2-1. 

This mitigation measure is regarded as better than the mitigation 

measures that have been implemented for similar projects. 

GCU to have an open-door policy and continue engagement to minimize 

impacts to tourism operators. This is regarded as consistent with similar 

project precedents. 

GCU to open to explore collaborations and win-win scenarios with 

interested outfitters. GCU wishes to explore the establishment of a 

stakeholder working group with Terms of Reference that are similar to 

those of a Local Citizen’s Committee for a SFL. 

GCU has moved the bridge to a downstream location so it is not visible to boaters from the upstream direction during normal 

water conditions due to rapids. Refer to Photograph 6-1 in Section 6. GCU has made best efforts to mitigate this issue. 

July 2013 Page 32




Summary of Issue GCU View and Mitigation Measure(s) Status (1) / Implementation Strategy 

10. Social issues created in 

First Nation community of Cat 

Lake as a result of all-weather 

access road to their 

community (drug smuggling). 

11. Noise and light pollution 

from the work site disturbs 

fishing outpost guests 

12. Impacts to fish habitat, 

particularly in the vicinity of the 

Birch River crossing 

13. Impact to water quality in 

Springpole and Birch Lakes 

during exploration and mining 

phases of the project 

14. Increased access to the 

area resulting in increased 

break-ins and vandalism of 

remote cabins. 

15. Impacts to caribou and 

their habitat 

16. Increased angling pressure 

on Springpole Lake due to 

GCU personnel. 

GCU shall endeavour to restrict all access to the Birch River system from the road through bridge design, which would 

make it very difficult to launch a boat into the river at or near the bridge. GCU will also seek to secure tenure of the land 

through a Land Use Permit at the end of the approved FMP portion of the road to allow construction of a gate at this 

location, effectively restricting access into the area north of this point. 

GCU maintains an open-door policy in order to receive concerns so that the specific sources can be identified and 

addressed. Mitigation measures are currently being evaluated, which may include but are not necessarily limited to: 

replacement of back-up alarms with after-market "white noise alarms" or strobe lights on heavy equipment, improved 

mufflers on heavy equipment and positioning of muffler exhausts lower to the ground to reduce the distance that noise 

travels, construction of housing around genset and other stationary noise sources, acoustic insulation in engine housings of 

mobile equipment, enclosures/barriers around drill rigs and implementation of special procedures to reduce the noise from 

rod handling. GCU will ensure that lights are angled downward and/or shroud the light sources to minimize straying. 

The proposed Project consists of timber harvesting and corridor construction with water crossings. This is routine work that has 

been conducted in Ontario for decades and the environmental protection measures are well-proven and established. GCU shall 

adhere to the best practice guidance documents referenced herein. GCU has adequate staff to ensure these prescriptive 

environmental protection requirements will be followed during project execution. As well, GCU is committing to having the Project 

overseen by a qualified professional and a compliance audit by a Registered Professional Forester following construction of the 

road. 

GCU has installed a best-in-class sewage treatment plant to service the tent camp. GCU's current preliminary exploration 

activities respect the applicable government requirements from MNR, MOE and DFO. If a production phase is proposed, 

GCU will first have to complete a comprehensive environmental assessment, then obtain several prescriptive approvals that 

will require a rigorous end-of-pipe sampling and lake sampling program to ensure that water quality is maintained within the 

stringent government requirements throughout the entire course of the construction / mining / closure development 

sequence. In addition, GCU would comply with the mining sector legislation including the federal Metal Mining Effluent 

Regulations and the provincial MISA regulation 560/94 under the Environmental Protection Act. Before the mine could open 

up, financial assurance would have to be provided to MNDM with a closure plan, pursuant to Part VII of the Mining Act. 

Together, this provides a prescription to rehabilitate the land and the money to carry out the rehabilitation work. The site 

would not become a negative environmental legacy in the area nor would it become an orphan site. Any additional Project 

scope beyond what is described herein would be subject to a new EA and approvals process. MOE is the lead provincial 

agency regarding water quality. 

GCU will seek a Land Use Permit for the land at the end of the approved FMP portion of the road to allow construction of a 

modern, monitored gate at this location, effectively restricting all access into the area north of this point. However, it is often 

regarded that theft and vandalism takes place using snowmobile more than highway vehicles, in which case the Project will 

not materially affect unlawful access to the region. As well, the majority of the camps in the area are centered on Birch or 

Springpole Lakes. Currently, Birch and Springpole lakes are exposed to uncontrolled winter access along GCU’s ice road 

over Birch Lake (refer to Figure 1-1 and 2-1). The eastern corridor lessens this issue for these camps because the only way 

to access Birch Lake from the proposed eastern corridor would be to travel directly through GCU’s private land and camp. 

The area north of Springpole Arm is regarded as "intact" caribou habitat and development proposals within such areas are 

generally unwelcome. To mitigate residual negative impacts associated with the proposed road, GCU intends to enter into 

an agreement with the MNR in order to ensure that this Project results in an overall benefit to the species. 

In addition to staff abiding by the Ontario recreational fishing regulations that are enforced by MNR in the region, GCU is 

developing an internal conservation fishing policy to protect the fishery and this will be enforced by GCU supervisors. GCU 

is also seeking to minimize destructive sampling during its on-going baseline monitoring programs. 

GCU has made best efforts that are within its authority to mitigate this 

issue. GCU has a drug and alcohol free workplace policy in place for the 

Springpole Gold Project. 

GCU shall make best reasonable efforts to mitigate this issue. GCU shall 

better publicize proper contact people so that GCU’s open-door policy is 

better implemented and GCU can better respond to these issues. 

Adhere to MNR and DFO guidance documents described herein and the 

AOC prescriptions in the FMP. As these are well-proven and established, 

GCU regards this issue as resolved pending further feedback. 

Adhere to MNR and DFO guidance documents described herein and the 

AOC prescriptions in the FMP. As these are well-proven and established, 

GCU regards this issue as resolved pending further feedback. 

Any additional Project scope beyond what is described herein would be 

subject to a new EA and approvals process. 

GCU shall use best efforts that are within its control to mitigate this issue 

including formalizing the monitoring and reporting to government and 

neighbours that is already in place. 

Outreach and engagement with relevant stakeholders is on-going. 

Currently involved in Overall Benefit permitting process under section 17 

of the Endangered Species Act (refer to Section 3.4). 

Consultation currently in process with MNR to develop a conservation 

fishing policy for GCU personnel to protect the fishery. 

Indicates that issue is outside scope of this Class EA process. In order to provide full disclosure of issues regarding the Springpole Gold Project that GCU is responding to, all issues that have been identified to GCU are described 

herein. 

(1) Issues are regarded as being resolved in a reasonable manner by either modifications to the proposed Project (refer to Section 5) or through on-going good-faith commitments described in Table 3-2. 

July 2013 Page 33




Table 3-3: Summary of Supportive Comments 

Comment Background Information Origin of Comment 

1. Eastern corridor is favoured due to access bait 

fishery. 

2. No opposition to either corridor as long as no 

outfitters unreasonably impacted. 

3. Project would be good for economy in the region and 

would create more of a tax base. 

4. Commitment to a net overall benefit for the 

environmental and biological values in the region is 

acknowledged. . 

5. Impact mitigation measures are reasonable and 

appropriate. 

Provided bait fishery area can be accessed from the road. Would appreciate a by-pass road around the 

camp area rather than having to go through GCU’s camp. MNR would have to consent to access. 

Commercial bait fisherman 

Tired of outfitters from outside Canada opposing all development in the region. Remote tourism operator 

The downturn in the forestry sector has negatively affected the region and a mine would help offset this 

loss of jobs and tax revenue. 

In agreement with the road, provided that there is continued dialogue on the road and all future project 

developments. 

No issues identified with the proposed Project, believes GCU is proceeding in an open and transparent 

manner; no concerns from their membership 

Township of Ear Falls, Municipality of Red Lake 

(most proximal municipalities to the Project) 

Métis Nation of Ontario (refer to Section 3.1.3). 

Proximal Tourist Operator 

Local Trapper’s Councils 

6. No comments or concerns with the report Provincial Ministry 

7. Project would provide improved safety for workers 

accessing the Springpole Gold Project 

It is an exciting project; good to eliminate the ice roads and find a safer route to the site. Provincial Ministry 

8. Wants to see the Springpole Gold Project proceed, 

which would be good for the local area. 

9. Support for the conclusions of the report and 

construction of the access corridor. 

10. One route servicing two (2) industries is an efficient 

and effective way to reduce potential impact in this 

area. 

In full support of the Project. Will bring employment to the local area; looks forward to seeing the 

Springpole Gold Project proceed. 

Project plans minimize or mitigate environmental concerns, access route will not negatively impact tourist 

operators or other industrial of recreational parties in the area; rehabilitation of road is proposed should 

the Springpole Project not proceed 

The route follows the planned road in the 2009-2019 FMP, which is consistent with habitat planning for 

caribou 

Local business owner 

Local prospectors’ organization 

Local business in another industry 

Encourage GCU to install water crossings that are sufficient for two (2) way, heavy traffic. 

11. The road is in a good location and will be good for 

the area. 

Registered trapline owner 

12. The proposed road corridor is located well for Cat The access corridor is in a good location to be extended to the community of Cat Lake. They are very 

Lake in relation to their future construction of an allweather 

interested in having a First Nation based/partner company complete the access corridor construction. Cat Lake First Nation community member 

road. 

This will bring jobs and contracts to the community. 

13. In support of the road and the Project in general. The Springpole Project has provided jobs and has been good for the community. Slate Falls First Nation community member 

14. No concerns with the proposed project. Interested 

Several community members from each of CLFN, 

n/a 

in job opportunities with the Springpole Gold project. 

SFFN and LSFN 

July 2013 Page 34




Domtar has provided a letter of support for the project and has provided information from the Trout 

Lake Forest FMP to facilitate GCU’s Project planning and to ensure harvesting and road 

construction are in accordance with Domtar’s plans for the Trout Lake Forest. It is recognized that 

the Project would assist forestry operations associated with the approved 2009-2019 FMP by 

harvesting timber and constructing a winter operational road in the approved road corridor with water 

crossings that are built to a primary road standard, pursuant to approval from MNR. As well, the 

Project would have synergies with future proposed FMP road extensions north of the Birch River 

crossing, as presented in Figure 2-2. GCU is consulting with Domtar to ensure the proposed Project 

does not hinder or interfere with future road building plans in the FMP. Further details regarding the 

conventional road construction methodologies that are proposed are provided in Section 5.1. 

3.3 Government 

Pre-submission consultation was initiated with government agencies regarding the Project in Q1 

2012 and continues on an informal basis. 

MNR has confirmed the category of the Class EA that is required, pursuant to MNR (2003), as being 

Category C. 

GCU participated in an interagency meeting on 16 April 2012 to review the Project. The meeting 

included participants from GCU, Ministry of Northern Development and Mines, Ministry of Natural 

Resources (“MNR”), Department of Fisheries and Oceans (“DFO”), Ministry of the Environment 

(“MOE”) and Transport Canada. An overview of the plans for the access corridor construction and 

on-going exploration work at the Project site was presented by GCU and input was received from 

the various agencies regarding the compliance obligations and permits required for the Project. 

3.4 Regulatory Approvals Process 

This Report and the Class EA process applies solely to the Project described herein. In the event 

that GCU proposes to advance the Project beyond the scope described herein, an entirely new EA 

and approvals will be required. 

3.4.1 Provincial 

MNR has confirmed the category of the EA that is required, pursuant to MNR (2003), as being 

Category C. Despite the routine nature and short duration of the proposed Project, the category of 

the Class EA was elevated from a Category B due to anticipated concerns from the tourism 

operators in the region as well as anticipated potential concerns from Aboriginal communities. A 

successful “bump-up” request (request for Part II Order) to the Minister of the Environment could 

make this exploration project subject to an environmental assessment under the Environmental 

Assessment Act, although this would potentially contravene the province’s objectives related to the 

encouragement of responsible mineral exploration (refer to Section 1.3). Prior to the issuance of any 

approvals for the Project, completion of the appropriate category EA is required. 

Where there are outstanding concerns about the Project that cannot be resolved in 

discussion with the MNR, concerned parties have an opportunity to formally request the 

Minister of the Environment issue a Part II Order requiring the Project to be subject to an 

individual environmental assessment under the Environmental Assessment Act. As this decision 

rests with the Minister of the Environment, parties should direct their inquiries in this regard to the 

Minister of the Environment. 

July 2013 Page 35




Minister of the Environment 

135 St. Clair Ave. West, 12th Floor 

Toronto, ON M4V 1P5 

Requests must be received by the Minister within the 30-day comment period, which expires on 2 

April 2013, and copied at the same time to the MNR contact person at the address below. 

David New 

Red Lake South Area Supervisor 

Ontario Ministry of Natural Resources 

P.O. Box 5003 

Red Lake, ON P0V 2M0 

Phone: 807-727-1383 

Fax: 807-727-2861 

Email: dave.new@ontario.ca 

Pending successful completion of this EA process, execution of the Project will require the provincial 

approvals listed in the bullets below. 

 

 

 

Crown Forest Sustainability Act: Forest Resource License to harvest Crown owned timber. 

An estimated (stand volumes to be provided in permit application). 

Public Lands Act, Lakes and Rivers Improvement Act: Letter of Authority for road 

construction, minor water crossings on Crown land. In addition, GCU is seeking a Land Use 

Permit to allow GCU to install a gate at the end of the FMP Approved Road (refer to Figure 

2-1). 

Endangered Species Act Section 17(c): C-Permit (Overall Benefit Permit) for Woodland 

Caribou 

The proposed work will adhere to the mitigation measures in the guidance documents listed in the 

bullets below. 

 

 

 

 

MNR (1988) and MNR (2010) in relation to AOCs and harvesting of merchantable timber. 

MNR (1995) in relation to water crossings and road construction. 

MNR (1996) in relation to winter culvert installation. 

Approved, specific AOC requirements in the Trout Lake Forest FMP. 

3.4.2 Federal 

The sole federal authorization that will be required for the Project is the approval pursuant to the 

Navigable Waters Protection Act for the water crossing over the Birch River. 

The proposed work will adhere to the guidance documents listed in the bullets below. 

 

 

 

Current DFO Operational Statements for clear span bridges and mineral exploration. 

DFO (1995) in relation to pump intakes. 

Wright and Hopky (1998) in relation to any blasting activities near the Birch River crossing. 

July 2013 Page 36




GCU has engaged DFO regarding the proposed water crossings and the well-established impact 

mitigation measures that are required to avoid a negative impact to fish habitat. 

4.0 ENVIRONMENTAL SETTING 

Baseline and technical studies were initiated in 2011 in order to define constraints to current 

activities and to support potential future EA processes and permit applications. The initiation of 

these studies does not indicate that a positive production decision is imminent. As is often the case, 

these studies have been initiated by the proponent in the event that the Springpole Gold Project is 

proposed to progress beyond the exploration and resource definition stage. On-going areas of study 

are listed in the bullets below. These areas of study were not undertaken to support this Project EA 

and approvals process and they are not required to understand the Project or its potential effects. 

The technical studies that are relevant to the proposed Project have been included in this Final ESR 

document. 

 

 

 

 

 

 

 

 

Meteorology, air quality and noise 

Hydrology and hydrogeology 

Geochemistry 

Terrestrial resources 

Fisheries resources 

Sediment, benthos and surface water quality 

Socio-economic 

Archaeology 

For brevity, a detailed technical description of the above noted baseline studies is not included 

herein. Further details and copies of reports may be made available by GCU upon request when 

these reports are finalized in ~2014. 

A Stage 1 and 2 Archaeological Assessment has been completed for the Project area. Additional, 

focussed archaeological assessment was undertaken in the vicinity of the Birch River crossing and 

south of Dole Lake to ensure that archaeological sites in these areas would be avoided by the 

access corridor. 

To date, Aboriginal communities have not identified the presence of sites of cultural heritage 

significance in the vicinity of the Project area. Technicians from the First Nations communities of Cat 

Lake, Slate Falls and Lac Seul have participated in and been employed by the on-going exploration, 

biological assessment and archaeological assessment programs (refer to Section 3.1). Outreach is 

has been initiated with Wabauskang First Nation and the Métis Nation of Ontario regarding 

opportunities to work together on the on-going values assessment and baseline program. 

It is GCU’s intention to continue on-going refinements to a constraints map to show the location of 

any biological, archaeological and cultural-heritage values so that these areas can be protected 

during the current exploration work and also during any potential future development. 

With participation of First Nation technicians (Cat Lake, Slate Falls, Lac Seul), DST initiated a 

desktop review and on-going field campaign in 2011-2012 to identify biological values and Species 

at Risk in the vicinity of the Project site that warrant consideration and may pose a constraint to 

July 2013 Page 37




future potential development activities. Woodland caribou have been identified as the Species at 

Risk (“SAR”) that is of most concern, with wolverine and eastern Whip-poor-will identified as the 

other potential SAR of concern. Field studies shall continue in 2013, in collaboration with 

government agencies, to ensure adherence to the provincial Endangered Species Act. It is intended 

that GCU’s on-going monitoring program will enhance the understanding of the species, this caribou 

range and MNR’s management plans for the region. 

DST (2012) in Appendix 4 provides a description of the environmental setting of the Project area as 

well as a comparative biological effects assessment of both access corridors. This report also 

describes measures to mitigate potential negative effects and it assumes that these are 

implemented for the purpose of determining the significance of residual effects. DST (2012) includes 

a review of the NHIC and NRVIS databases. DST (2012) is provided in its entirety in Appendix 4 for 

full disclosure and is not reproduced within the body of this Report for brevity. 

4.1 Current Land Use and Archaeological Values 

The Property is within the Red Lake Mining District, Casummit Lake area and is presented on 

Ontario Base Maps 54005690, 55005690, 56005690, 54005680, 55005680, 56005680, 54005670, 

55005670, 56005670 (1:20,000 scale). The Property is entirely within the Trout Lake Forest 

Management Plan and south of the lands that are subject to the Cat Lake First Nation and Slate 

Falls First Nation Land Use Plan (Cat Lake First Nation et al., 2011). The Property is not subject to 

Ontario’s Far North Act. 

The use of the lands within and adjoining the Property is generally wilderness / recreation and 

natural resource extraction (i.e. mineral development, forestry). The Property has been subject to 

preliminary exploration activities explored on an intermittent basis since the 1920s. The MNR Crown 

Land Use Policy Atlas indicates that the area is designated as a General Use Area (G2514). The 

project area lies within MNR EcoDistricts 3S-2 and 3S-4 and within the Upper Albany - Cat tertiary 

watershed. There are currently no amendments in progress in the map area. A Conservation 

Reserve is located to the south east of the Property at Christina Lake. 

Domtar currently holds the Sustainable Forest License (“SFL”) for the Trout Lake Forest and is 

active in the region. The planned extension of the Wenasaga Road, scheduled to be constructed as 

early as 2014 according to the 2014-2019 Trout Lake Forest Management Plan (“FMP”), connects 

with the southeast portion of the Property (refer to Figures 2-1 and 2-2). This portion of the 

Wenasaga Road and the planned extension is within the vast 2011 wildfire area and so harvesting 

will need to commence in the near-term in order to salvage the standing timber before it is rendered 

uneconomic due to decay. 

There are no Environmental Sensitive Areas or provincially significant wetlands in the immediate 

vicinity of the Property based on biological assessment work and consultation with MNR to date. The 

region is known to provide woodland caribou habitat and the area is subject to management for this 

species at risk. This species is of particular concern because it is regarded as a species that is 

indicative of overall ecosystem health and integrity. 

There are numerous tourism businesses operating in the area of the Wenasaga Road extension 

and the Property, including KaBeelo Lodge, Pickeral Arm Camps, Fort Frances Northern Wilderness 

Outfitters, Hidden Bay Lodge, KayAir Service, True North Outpost and Camps, Green Airways, Birch 

July 2013 Page 38




Lake Lodge and Red Pine Lodge and Outposts. There are also several private landowners on 

Springpole Lake in the general vicinity of the Deposit that GCU is in the process of engaging 

regarding the Project. 

Horizon completed a Stage 1 archaeological assessment for the Property and two (2) potential 

access corridors in early 2012. With participation of First Nation technicians (Cat Lake, Slate Falls, 

Lac Seul), Horizon then completed Stage 2 and Stage 3 assessment work to identify archaeological 

values in the eastern corridor so that these areas can be avoided by GCU’s proposed Project (refer 

to Appendix 2 and Section 5). 

4.2 Climate 

A meteorology station was installed adjacent to the existing camp location to determine local climate 

patterns. Noise monitoring occurred at three (3) stations throughout the Project area to create a 

baseline data set. 

The closest climate station to the Project site is located at the nearby Red Lake airport, 

approximately 120km to the west-southwest. Average temperatures normally range from a low in 

February of -19.6˚C to a high in July of between 18.1˚C and 23.3˚C. The average annual 

precipitation for the year is 640.2 mm, with the expected minimum precipitation being 18.6 mm in 

February, and the expected maximum being 97.7 mm in June. At the Red Lake weather station, 

monthly wind speeds for the area are generally stable throughout the year, averaging approximately 

9.4 to 12.8 km/h. The prevailing winds are generally from the northwest, which would direct air and 

noise emissions away from the nearest receptors located to the northwest and northeast of the 

Project site. 

4.3 Surface Waters 

The vicinity of the Deposit overlies and surrounds the northern headwater portion of Springpole 

Lake. Regionally, Springpole Lake flows southeast via Birch River to the Albany River system and 

ultimately drains to the Arctic Ocean. Springpole Lake supports a cool water and cold water fish 

community. 

Surface water monitoring has occurred quarterly throughout the study area on Springpole, 

Seagrave, and Birch lakes as well as a small unnamed pond between Springpole and Birch lake. 

Sampling began in winter 2011. Sediment and benthic invertebrate collections occurred in the fall of 

2011 on Springpole, Seagrave, and Birch lakes as well as two small unnamed ponds between Birch 

and Springpole lakes. 

Automated gauge stations were established in five (5) watersheds in the Project area to monitor 

stream depth. Manual measurements of flow and depth were taken periodically throughout the year. 

The manual measurements and stream depth recordings were used to produce a discharge curve 

for each location. This study relates to future potential development proposals and not the Project 

that is the subject of this Report. 

Draft factual reports have been prepared and engagement with the Aboriginal communities is 

anticipated prior to finalizing these reports. 

July 2013 Page 39




4.4 Ground Water 

The hydrogeology of the region is predominantly controlled by the exposed bedrock or the overlying 

cover of native clay soil. Shallow ground water flow is assumed to be similar to surface drainage, 

primarily originating at the heights of land and flowing radially downslope. 

4.5 Soils 

Soils for the Project area are described in several Ontario Geological Survey publications and 

Northern Ontario Engineering Terrain studies. 

 

 

Based on Ministry of Northern Development and Mines Quaternary Geology of Ontario, 

West Central Sheet, Map 2554 (Scale 1:1,000,000), subsurface conditions in the region 

consist of undifferentiated till of predominantly sand to silty sand. 

Based on Ministry of Northern Development and Mines Bedrock Geology of Ontario, 

West Central Sheet, Map 2542 (Scale 1:1,000,000), bedrock geology at the site consists 

of mafic metavolcanic and metasedimentary rocks and minor iron formation. 

There is generally low to moderate relief in the vicinity of the Springpole Gold Project, with generally 

dry uplands and poorly-drained lowland valleys with thick accumulations of organic soils. In this 

region, soils are predominately grey wooded and podsols on well-drained sites as well as peats and 

gleysols in poorly-drained areas. 

4.6 Terrestrial Plant and Animal Life 

The Property is part of the Lac Seul Upland, which extends eastward from Lake Winnipeg in 

Manitoba to the Albany River in northwestern Ontario. Forest composition in the Property is typical of 

the Lac Seul Upland. Predominant tree species are trembling aspen, black spruce, with some white 

birch, balsam fir, and white spruce. Understory ground cover species composition and abundance is 

typical of mesic mixedwood boreal sites, and lacks microhabitats likely to harbor rare vascular plant 

species. A variety of common, early successional, graminoids and herbaceous ground cover plants 

are prevalent on areas of the Property where mature timber has been removed or where the canopy 

is open and the ground is exposed to light. Natural re-vegetation and succession has been observed 

to be rapid at the Property in areas of historical exploration. 

DST has been conducting baseline environmental work at the Springpole Gold Project area since 

2011. Draft factual reports have been prepared and engagement with the Aboriginal communities is 


With respect the proposed Project, DST has prepared a biological constraints report to compare the 

effects associated with the two (2) corridor alternatives. A draft of this report is provided in Appendix 

4. A supplemental letter report from DST is provided in Appendix 5 to present the results of a winter 

2013 aerial survey. During this aerial survey no caribou were observed in the vicinity of the Project. 

Commencing in 2012, supplemental field studies have been conducted with input from MNR to 

ensure adherence to the provincial Endangered Species Act. If any habitat use by SAR is identified 

during 2012 field surveys, MNR will be consulted to identify any required mitigation measures. If 

required, mitigation measures that may be employed may include, but are not limited to, those that 

are listed in the bullets below. 

July 2013 Page 40




 

 

 

 

Habitat conservation by modifying the development footprint, the activities and/or the timing 

of activities at the Springpole Gold Project site. This may include avoiding earthworks / 

clearing activities outside the existing footprint during the period when SAR (e.g. breeding 

birds) could be present and these work windows would be established with input from MNR. 

Public education regarding the relevant SAR to increase awareness and conservation efforts 

in the region. 

Conduct and/or fund monitoring programs to increase the understanding about the relevant 

SAR, which would facilitate the refinement and implementation of management plans. 

Habitat enhancement and/or creation (e.g. planting appropriate vegetation and targeted 

silvicultural prescriptions; vehicle and equipment management to reduce likelihood of 

collisions; management of off-road vehicles to reduce likelihood of disturbance to ground 

nests; set-aside areas for habitat creation; nest creation; etc.) at the Property or elsewhere in 

the region off of GCU-controlled lands. 

Mitigation measures would be implemented in a multi-species context as necessary. Mitigation 

measures would be implemented with input from MNR and in accordance with any permits that may 

be issued pursuant to the Endangered Species Act. 

Migratory birds are likely to be present in the vicinity of the Project site. As described herein, GCU 

proposes to conduct its tree harvesting during the winter windows while migratory birds are not 

present and nests are not active, as appropriate, and in consultation with MNR. 

4.7 Aquatic Plant and Animal Life 

DST has been conducting baseline environmental work at the Springpole Gold Project area since 

2011. Draft factual reports have been prepared and engagement with the Aboriginal communities is 


With respect the proposed Project, DST has prepared a biological constraints report to compare the 

effects associated with the two (2) corridor alternatives. A draft of this report is provided in Appendix 

4. 

4.8 Local Air Quality, Noise and Light 

The Project site is located in a remote area of northwestern Ontario. There are no adjoining 

anthropogenic sources of industrial air emissions. Potential nearby sources of noise and air 

emissions include forest fires, combustion products from heating oil and propane that are used for 

residential and recreational purposes at the numerous tourist lodges and periodic timber harvesting 

activities in the Trout Lake SFL. 

GCU is endeavouring to do further outreach and communicate its open-door policy so that nearby 

parties can contact GCU if there are concerns related to the Springpole Gold Project. GCU intends 

to mitigate concerns to the extent practical. 

4.9 Socio-Cultural Setting 

Mineral exploration, mining, mining spin-offs, forestry and wilderness tourism (hunting, fishing) 

comprise the majority of economic activity in the area. The forestry industry has experienced a 

downward cycle for several years and contributions to the regional economy have been significantly 

reduced. 

July 2013 Page 41




The Red Lake area has been an historic mining camp since the gold rush of the 1920s, and it 

currently has five (5) active mines and numerous decommissioned / abandoned mines situated 

within the Municipality of Red Lake. The mining and mineral development sector is the largest 

employer in the region. 

Contingent on successful financing, the on-going near-term exploration and evaluation work would 

result in annual expenditures on the order of millions to tens of millions of dollars. Based on 

experience to date, at least two thirds of these expenditures would accrue to the surrounding region 

and support the local economy of northwestern Ontario. 

Mineral exploration is not a scientific or recreational pursuit, it is a necessary means to an often 

desired end (i.e. a producing mine). Although a producing mine is outside the scope of this EA 

process, a producing mine is the objective of every exploration project, establishing new mines is a 

provincial government objective (refer to Section 1.3) and so aspects of a producing mine are 

regarded as appropriate context for this EA. 

A producing mine would be significant to the local economy and taxation base. While the 

actual characteristics of the potential production phase could differ from this, benchmarking 

of other gold mining projects across the province suggest that the employment created 

would represent a >10% increase in the current total primary and manufacturing industry 

employment level in the Red Lake / Ear Falls region. 

The provincial and federal governments would be principal beneficiaries, through new 

revenues generated through employee income taxes and other employee-related 

government-mandated contributions (e.g. to Canada Pension Plan, Employment Insurance 

Program, Employee Health Tax and Workplace Safety and Insurance Board). These senior 

levels of government would also enjoy additional revenues through value–added sales, 

corporate income, capital and other taxes levied on the corporation. 

These benefits do not include the voluntary contributions to the local and Aboriginal 

communities that are commonplace with large scale resource development projects once a 

revenue stream is achieved, consistent with the tenets of modern corporate social 

responsibility. 

Ontario recognizes the importance of mineral development opportunities to northern Ontario, as 

summarized in Section 2. 

The Project objective of establishing improved access for a mineral development project is aligned 

with Ontario’s objective of encouraging mineral development opportunities, particularly for resource 

definition projects such as the Springpole Gold Project. Furthermore, the preferred alternative 

corridor presented herein would conform to the provincial objective of being a leading example of 

progressive environmental stewardship as summarized in the bullets below. 

 

 

Maximizing synergies with other planned and potential resource development projects such 

as Domtar’s planned Wenasaga road and a potential all-weather road to Cat Lake First 

Nation. 

Minimizing potential cumulative impacts to terrestrial habitat and remoteness values by 

avoiding a second linear development in the region and following a recent wildfire area 

rather than an area of unaffected tract of forest. 

July 2013 Page 42




 

Minimizing potential impacts to archaeological values by selecting a route with a lower 

potential to host archaeological values. 

The Springpole Gold Project represents a significant economic opportunity that, if developed, would 

create well-paying, long-term employment opportunities in the region, positively contributing to the 

local economy, community and government tax base. 

Letters of support for the Springpole Gold Project are being received from the Township of Ear Falls 

and the Municipality of Red Lake, which are the two (2) proximal municipalities to the Project. 

5.0 PROJECT DESCRIPTION 

The Project essentially consists of road-building and timber clearing. In order to avoid “re-inventing 

the wheel,” GCU intends to adopt the AOC prescriptions and other requirements in the FMP in order 

to follow precedents for these activities within the Trout Lake SFL. 

GCU has undertaken a large scale 2011-2012 program to define the biological and archaeological 

values at the Property with direct participation from First Nations technicians. These on-going efforts 

are intended to inform GCU of the values in the region so they can be protected during the course of 

on-going exploration activities and future potential development activities. 

The values mapping and on-going outreach program have resulted in the adoption of a variety of 

mitigation measures, which are well-established due to the common nature of this Project. In the 

interest of simplicity, ease of implementation and enforceability by MNR, these mitigation measures 

have been directly integrated into the methodology for the Project where practical, as described in 

Section 5. However, specific mitigation measures are summarized in Section 6 and GCU also 

remains open to entering into a reasonable Resource Stewardship Agreement that is in line with 

precedent agreements, as indicated in Table 3-2. 

Despite the extensive archaeological assessment work completed to date and the clearance of the 

Project corridor by Horizon (refer to Section 4.1), GCU will follow the Chance Find Procedure 

defined herein (refer to Definition of Terms and Acronyms) and this may necessitate minor 

modifications to the road alignment within the 500m wide corridor presented on Figure 2-1. If GCU 

modifies the location of the ~15 m wide road right of way (“ROW”) within the 500 m corridor 

presented on Figure 2-1, these minor modifications will be documented to MNR and will be reflected 

in the permit applications that follow the EA process. Prior to construction, any potential minor 

modifications to the ~15 m wide road ROW within the 500 m corridor will be cleared of 

archaeological values by a licensed professional archaeologist, in accordance with prescriptive 

standards and guidelines for consultant archaeologists from the Ministry of Tourism and Culture, 

with documentation provided to MNR. 

The Project is a subset of the Springpole Gold Project, as defined herein. In the event that the 

Project is approved and executed, the seasonal ice road over Birch Lake (refer to Figure 2-1) would 

be discontinued. 

The Project proposal is independent of the activities that are approved in the Trout Lake FMP and 

there are no collaborations with the SFL holder regarding road construction. 

Although the on-going exploration activity is outside the scope of this EA process, the current 

planned area of intensified mineral exploration is shown on Figure 2-1. 

July 2013 Page 43




5.1 Construction 

Winter time construction methods will allow GCU to construct the road during a period that will 

minimize impacts to outfitters, species at risk and migratory birds. As well, winter is a conventional 

low water period and is typically when stream flows are minimal. Although the water crossings 

associated with the road will be constructed to a primary road standard, the road will be built to a 

winter operational road standard to facilitate rehabilitation and decommissioning if the Springpole 

Gold Project does not advance beyond the current exploration stage. The road layout and 

construction will follow principles outlined in the documents listed below. 

Environmental Guidelines for Access Roads and Water Crossings (MNR, 1995) 

Forest Management Guide for Conserving Biodiversity at the Stand and Site Scales (MNR, 

2010) 

Crown Land Bridge Management Guidelines (MNR, 2008) 

MNR Guidelines for Culverts Installed in the Winter (MNR, 1996) 

Department of Fisheries and Oceans Operational Statement for Clear Span Bridges 

Forest Road Engineering Manual (British Columbia Ministry of Forests, Lands and Natural 

Resource Operations, March 2013) 

Domtar’s 2009-2019 Trout Lake Forest Management Plan 

Domtar’s Trout Lake Forest Road Construction Standard Operating Procedures as outlined 

in their Forest Products Environmental Management System 

A typical road cross section is provided in Photograph 5-1A. For comparison purposes and to show 

the required upgrades, a typical cross section of an (all-weather) primary road is provided in 

Photograph 5-1B. This figure is included to show how Domtar (the SFL holder), or any other party, 

could upgrade the FMP Approved Road portion from winter road to primary road standard. GCU has 

consulted with Domtar to ensure the proposed Project does not hinder or interfere with future road 

building plans in the FMP. 

The base case construction schedule, proposed construction methods and mitigation measures are 

summarized below. These would be further described in any subsequent permit applications for the 

Project. 

September - October 

Procure goods and services to carry out the Project, contingent on successful acquisition of 

approvals and timing restrictions. Entering into contracts that are contingent on successful 

acquisition of permits is fraught with uncertainty, financial risk and this may delay execution 

of the Project. 

Decommissioning of historic mineral exploration trails, as generally indicated in Figure 2-1. 

Trails will be taken out of service and measures implemented to establish vegetation. 

Use off-road vehicles to access the corridor and confirm the layout of the winter road. 

o This road corridor has been walked and flagged by a qualified road contractor 

several times during 2012 in various seasons from spring to midsummer to fall and 

early winter (the contractor has observed the drainage and water levels throughout 

the year). The contractor has identified all the water crossings and cross drainage 

locations in the field and has physically marked the stream beds to aid in winter 

culvert installation. Of the 14 identified stream crossings only seven (7) were 

indicated on the 1:20,000 Ontario Base Maps, the other seven (7) were identified by 

July 2013 Page 44




the road contractor. Furthermore the contractor has identified ~56 required cross 

drainage culverts to ensure natural drainage patterns are not impeded. GCU has 

ensured there will be no unexpected crossings encountered during the harvest or 

construction phase. 

1 November to 20 December 

Mobilize equipment to the end of the current Wenasaga Road. 

Establish rig mats that are frozen in ice at the Birch River crossing and the Dead Dog Creek 

crossing sites to facilitate crossing and eliminate the need to ford these watercourses or 

otherwise work in water. 

Harvest timber from end of current road at Dead Dog Lake to Birch River using a feller 

buncher (approximately 15 km) and conventional harvesting equipment. This is the Trout 

Lake FMP-approved Wenasaga Primary Road 82-6 and is within the 2011 wildfire area. The 

road right of way (“ROW”) will be 15 m wide except at the creek crossings where the primary 

road standard width of 20m will be used as per the Trout Lake FMP and Domtar standard 

operating procedures for primary roads. The lowland portions of the road will be corduroyed 

with the trees and brush that are cut within the ~15 m ROW. Any other trees not required in 

the road bed will be piled, but it is anticipated that all the trees will be used in corduroy brush 

mats. Domtar has indicated they do not require any trees from this operation and any piles 

not utilized will be burned. An excavator will follow the feller buncher to ditch the road, bankup 

the spoils from the ditching and track-pack a winter road. This will allow passage by 

highway vehicles during freeze-up times and off-road vehicles (e.g. skidder, quad, Nodwell 

brand or Prinoth brand off-road equipment) during other times of year. The crew will work 

night shift and day shift to keep equipment running and minimize freeze-up issues. The road 

standard is: 

o 

o 

o 

Clear trees and use trees and brush as required creating a brush mat 

approximately 8 to 10 m wide. Further details regarding road construction 

methods are provided in Figure 5-1A. 

With an excavator build a sub base from material used along the side of the 

brush mat to a depth 1 to 3 m and a ~4 to 5 m wide travel surface 

The brush mat prevents the road from sinking and separates the road base from the 

ground. This and the ditches helps water drain from the road base into the adjacent 

ditch. It creates a solid road under winter conditions that can be reused for several 

winters and also provides limited access the balance of the year. 

 

 

Best practice and Environmental Guidelines for Access Roads and Water Crossings (MNR, 

1995) require that natural drainage patterns be maintained. Accordingly, as the feller 

buncher advances, GCU will install cross culverts (no excavation required) using the 

excavator at the pre-determined locations that have been specified and marked in the field 

by an independent road building contractor. 

There are two (2) major water crossings along the ROW, Dead Dog Creek and Birch River. 

The other 12 identified crossings are all 1 m or less wide and less than 0.5 m deep. The two 

(2) major crossings are described below. The other minor crossings will have either the 

proper size permanent culvert installed or will be crossed with an engineered portable bridge 

or am engineered square timber bridge. Any culverts installed in winter will comply with MNR 

July 2013 Page 45




 

 

 

 

 

 

(1996). The bridges would be installed according to the DFO Operational Statement for 

Clear Span Bridges, the issued MNR permit(s) and any additional conditions required by 

MNR. 

o 

Birch River and Dead Dog Creeks are major crossings and will be designed as clear 

span structures (~35 m for Birch River bridge; ~12 m for Dead Dog Creek bridge, to 

be confirmed in applications that will follow the EA process), with site specific 

engineering drawings that comply with MNR and DFO standards. The bridges will be 

constructed in winter along with all of the other construction phase work. Bedrock 

that is excavated to construct the bridge abutments will be used as rip rap and to 

surface the approaches for water crossings. This material may be crushed if 

required. Blasting activities will be in accordance with Wright and Hopky (1998) and 

the portable crushing contractor will conduct work in accordance with provisions of 

the Environmental Protection Act. 

Utilize a rock truck (with a heated box) to import aggregate and use the excavator to place it 

over the installed culverts. Aggregate would be removed from the nearby FAPs for 

construction as needed for use on the FMP approved road (refer to Definition of Terms) 

only. 

Aggregate that is required for the road beyond the FMP approved road will be sourced 

from either existing excavations on GCU’s patents or from an existing aggregate pit that 

is licensed in accordance with the Aggregate Resources Act. The governing policy is 

provided at the following link: 

http://www.mnr.gov.on.ca/stdprodconsume/groups/lr/@mnr/@forests/documents/docume 

nt/275588.pdf 

One of the reasons GCU has included engineered square timber bridges as an option is 

because they require very little aggregate when installed. 

Aggregate that is used for rip rap or erosion protection will be screened to remove fines and 

ensure that it is cobble size material. 

Concurrent with the timber harvesting and road construction from the end of the Wenasaga 

Road, GCU would commence timber harvesting and road construction from GCU’s camp 

using heavy equipment that is currently in place at the camp. 

Utilize rig mats / swamp mats or an ice bridge to cross the Birch River with heavy equipment 

at the bridge location to begin the bridge installation. The DFO Operational Statement for 

clear span bridges would be followed. Alternatively, GCU would access the east abutment 

using the equipment that commences work at GCU’s camp. 

Approximately January 5 to March 15 

Finish constructing the Birch River bridge in accordance with the engineering design 

drawings, DFO’s Clear Span Bridge Operational Statement and any additional conditions 

required by MNR. There would be no structures below the normal high water mark. Although 

the crossing is not regarded as navigable except during unusually high water conditions, the 

bridge would be high enough to allow passage of boats beneath it and in accordance with 

requirements from Transport Canada. 

Place black muck (sourced from within road corridor) on the embankments of the placed 

road fill near the bridges and spread a seed mix with no invasive species before covering the 

surface with straw mulch, all in accordance with proven best management practice on 

July 2013 Page 46




forestry roads. The objective is to establish vegetation for erosion control and to minimize 

impacts to the local aesthetics, so this proven erosion control technique is preferred over the 

more costly placement of rip rap on fill embankments. Rip rap will still have to be used on 

and around cribbing to prevent scouring. As a construction objective that is still being 

evaluated, the height of the fill at the crossing will be minimized in order to minimize 

aggregate costs, to minimize impacts on the local viewscape and to facilitate the eventual 

rehabilitation of the road. 

Approximately March 15 to May 1 

Install a modern, monitored gate at the end of the existing FMP road, pending issuance of a 

Land Use Permit to GCU (refer to location in Figure 2-1). The gate is intended to mitigate the 

concern over increased access to the area. GCU wishes to prevent any more access to the 

region than what is already approved in the FMPs. Once the FMP Approved Road is 

extended by the SFL holder in accordance with the 2014-2019 FMP, the gate would be relocated 

to the end of the extended FMP Approved Road (refer to location in Figure 2-1). 

De-mobilize road building contractor. 

Gravel placement over this winter operational road and upgrading it to an all-weather access road is 

not part of the currently proposed Project. Pending continued positive exploration results and ongoing 

consultation, the gravel placement that would be required to upgrade this winter operational 

road to an all-weather access road may be proposed at a later date. 

The proposal outlines that Crown dues will be paid based on FRI volumes generated from the SFL 

holder’s wood supply modelling. GCU has no choice but to use this method: 

1. The SFL holder has confirmed they do not want this wood volume. 

2. The Resolute Mill in Fort Frances has been on shutdown from the fall of 2012 to July 

2013 and has only scheduled a temporary start-up of paper production in 2013 creating a 

surplus of wood in this part of northwestern Ontario. 

3. Based on FRI, 59% of the wood is burnt wood from recent fires. There is no market for 

logs for use in pulp, paper or sawlogs for wood that has been burnt 18 months ago. The 

combination of charred wood, insect and fungal damage has destroyed these logs for 

use in forest products. 

If the Project is approved, GCU would discontinue the seasonal ice road over Birch Lake, which will 

reduce access to Birch Lake. 

Engineering details, construction methods, sediment control plans and contingency plans are 

provided in Appendix 7. These details are typically reserved for Work Permit applications, but have 

been included herein for completeness. 

July 2013 Page 47




Photograph 5-1A: Typical Winter Road Cross Section 

July 2013 Page 48




Photograph 5-1B: Typical Primary Road Over Winter Road Cross Section 

July 2013 Page 49




5.2 Operation, Maintenance and Surveillance 

GCU proposes to primarily utilize the road when local outfitters do not have customers in their 

lodges. This active period for local outfitters is understood to be approximately mid-May to late 

October, depending on ice conditions and market conditions. 

Mineral exploration and resource definition is an iterative process that is often contingent on 

successful results, financing and commodity prices. As a result, it is difficult to precisely define the 

planned use of the proposed road for the next several years. However, GCU currently envisions use 

that will vary by season, as summarized in the bullets below. 

 

 

 

 

It is currently anticipated that three (3) to four (4) trips per week will be required to move 

materials and personnel to and from the camp during freeze-up conditions when the road is 

frozen. These trips will be via highway vehicles, either crew van or transport truck. This does 

not include periodic snow removal. 

Outside the freeze-up period, it is anticipated that no more than one (1) trip per week will be 

required to move materials to and from camp. GCU would use highway vehicles (likely a 5 

tonne highway truck with a boom) to travel as far as the end of the FMP Approved Road. 

The highway truck would transfer palletized equipment using a boom onto an off-road 

haulage vehicle (i.e. Nodwell, Prinoth or equivalent) with a flat deck to transport it to the 

camp. GCU is evaluating large tracked machines capable of a 15,400 kg payload. The 

machine and a full payload is a combined 27,000 kg and has a ground pressure of 4.65 psi, 

which is less than a typical human footprint. The off-road haulage vehicle could also be 

utilized to drag in equipment as required and drag out garbage for disposal. The off-road 

haulage vehicle would normally be posted at the GCU camp and would likely replace or 

augment the skidder that is currently used to move drill rigs. Personnel would be flown in 

and out during this time of year due to the high cost of haulage using off-road equipment. 

Despite this expensive form of haulage, the availability of a land-based corridor to the area 

of the Deposit will greatly improve GCU’s ability to mobilize / de-mobilize heavy equipment 

(including drill rigs), import bulk consumables and export garbage for disposal at an MOE 

approved facility. 

In addition to higher haulage costs during summer months due to the use of off-road 

equipment, the potential for rutting on the winter road due to use outside of the freeze-up 

period, there is a natural incentive for GCU to focus its utilization of the road during winter 

months when the road is frozen and can be travelled using highway vehicles. 

Road use restrictions that are imposed as a condition of the Overall Benefit permit (refer to 

Section 3.4) and any other legislative requirements would be respected. 

It is GCU’s practice to effectively containerize garbage and ship it off-site for disposal in an effort to 

avoid attracting bears or other predators to the exploration site. This practice would continue if 

access were improved, as described herein. 

If the Project is allowed to proceed, empirical evidence would be gathered by an independent 

consultant to quantify the effects of noise, vibration, light and fugitive dust on local users of the area 

(i.e. boaters on nearby lakes, occupants at nearby lodges, etc.). Empirical data that is gathered on a 

real-time basis at sensitive locations is preferable to sole reliance on predictive models. In parallel, 

GCU is evaluating proven techniques to control noise and fugitive dust that are typically associated 

July 2013 Page 50




with road use and would potentially eliminate any on-the-ground impacts to customers at the lodges 

in the region. 

In the event that a repair to the road becomes necessary (i.e. backfill a rut, repair a water crossing), 

GCU would engage the relevant outfitters regarding the preferred timeline for the repairs and then 

consult MNR regarding the need for any approvals to conduct the repair. GCU is attempting to stave 

off the need for any road repairs during the outfitters’ busy season by installing well-engineered 

water crossings and cross-culverts using qualified contractors. As described, the road as 

constructed will be useable in the summer by tracked machine and other low pressure bearing 

equipment (i.e. rock trucks). Any maintenance required at stream crossings will be completed with 

this type of machinery that will walk to the work site rather than be transported by float truck. 

The road is not anticipated to require any routine maintenance during the spring, summer and 

autumn months. During winter months, the road will be subject to snow removal activities when in 

use. 

GCU will monitor water crossings for the life of the road to ensure functionality and physical stability. 

Following construction of the road, GCU will conduct an audit of the work in accordance with 

standard forestry sector practice (refer to Section 8). Additional monitoring details are provided in 

the bullets below. 

 

 

Consequently there will be workers using the road and observing conditions while it is being 

travelled. To complement this, the GCU will make monthly inspections of the road and 

crossings to ensure crossings are not failing, and sediment and erosion controls are 

effective. 

Regarding any beaver problems, GCU will adhere to the Red Lake District protocol for 

removal of nuisance beavers and follow the procedure Domtar currently uses on the Trout 

Lake Forest. Local trappers identified by MNR will be contacted and used to remove the 

beavers. 

GCU has committed to making best efforts to utilizing the road during winter months and minimizing 

road use during summer months. GCU’s proposal to construct a winter operational road provides a 

natural incentive for GCU to adhere to this commitment rather than utilizing slow moving off-road 

haulage equipment with high operating costs during the summer months. 

5.2.1 Road Use Strategy 

The road beyond the FMP Approved Road is proposed to be utilized solely by GCU, pending 

direction from MNR, for a duration of three (3) years following the conclusion of the construction 

phase. Continued use of the road beyond this timeline would be pending commencement and 

outcome of a provincial EA for the development of the Deposit (refer to Section 5.3). 

The end of the FMP Approved Road will be gated with a modern, monitored gate. The gate will have 

a cardlock system to prevent unauthorized reproduction of keys and to require the closure of the 

gate by personnel in order to retrieve their passcard. Monitoring of the gate via inspections and 

cameras is planned. 

July 2013 Page 51




GCU would make best efforts so that any use of the road during the mid-May to late October window 

would be communicated to proximal outfitters a minimum of two (2) weeks in advance of the date. 

Emergency use (i.e. transport personnel to hospital) would not be communicated to proximal 

outfitters. 

Road use restrictions that are imposed as a condition of the Overall Benefit permit (refer to Section 

3.4) and any legislation would be respected. 

5.3 Decommissioning 

Exploration and resource definition work is an iterative process and timelines and activities are 

affected by on-going results. Recent exploration results have been very successful, as described in 

Section 1. Despite recent success, significant additional work is required to define the Deposit. 

Pending market conditions and availability of improved access to the Property in the near-term to 

facilitate on-going exploration work and installation of Property infrastructure, GCU expects to make 

a decision regarding the initiation of a provincial EA for the development of the Deposit before the 

end of the third year of use. A proposal to develop the Deposit into a producing mine would require 

an entirely new EA and approvals process. 

GCU is prepared to decommission the road by removing water crossings in accordance with MNR 

(1995) and regenerating the cleared corridor beyond the FMP Approved Road as per the Trout Lake 

Forest FMP approved Silvicultural Ground Rules based on forest unit. The regeneration will be 

addressed by the renewal fees paid to the Crown by GCU for the timber harvesting within the 

corridor. With respect to the water crossing removal, GCU accepts this responsibility and is 

prepared to provide financial assurance as described below. 

1. Financial assurance amount that is required for the water crossing removal will be 

determined by an independent Registered Professional Forester experienced in road 

building and decommissioning. A trust account with the required amount of financial 

assurance will be set up prior to starting construction of the water crossings. 

2. The cost to rehabilitate the road will be re-evaluated every three (3) years with any 

increases to be reflected in a “top up” of the trust account. 

3. MNR would be paid out the financial assurance amount from the trust account in the 

event of bankruptcy or insolvency. 

In the event that the Springpole Gold Project does not progress to the commencement of a 

provincial EA for the development of the Deposit before the end of the third year of use, defined as 

36 months following the conclusion of the construction phase (refer to Photograph 5-2). It is 

understood that some of other parties (Cat Lake First Nation, Domtar) may have an interest in 

having some or all of the road and water crossings beyond the FMP Approved Road remaining in 

place. However, this modified use of the eastern corridor would be subject to a new EA and 

approvals process by another proponent. 

In the event that the Springpole Gold Project becomes fully permitted and proceeds to a production 

phase, the rehabilitation of the access corridor would be subject to special conditions arising from 

the EA process as well as the subsequent approvals process. i 

July 2013 Page 52




For added clarity, the decision making process and timeline related to road decommissioning is 

illustrated below in Photograph 5-2. 

Photograph 5-2: Flowchart to Illustrate Road Decommissioning Timeline 

Year 1: Construct winter 

road in accordance with 

Final ESR and issued 

permits 

Initiate a new 

consultation process 

and Environmental 

Assessment (“EA”) 

for development of 

Springpole Gold 

Project with 

continued use of 

road while the new 

EA is in progress 

OR 

Outcome of new 

EA is that GCU 

should be 

allowed to seek 

permits for the 

development of 

a mine. 

Contingent on 

exploration results; 

market conditions, 

community feedback 

regarding Project 

Description 

(refer to Section 10). 

Outcome of EA 

process is that a 

mine should not 

be developed 

(“no-go” 

alternative) 

Following the 

completion of the 

construction phase, 

commence 3 year 

period of use for the 

winter road 

Springpole Gold 

Project does not 

progress 

Decommission road 

beyond the FMP 

Approved Road and 

remove GCU’s gate 

(1) 

GCU respects the road 

decommissioning provisions that 

are imposed by the new EA and 

permits for the mine. 

(1) If a third party acquires GCU’s interest in the road beyond the FMP Approved Road and 

obtains any necessary approvals from MNR, then the relevant portion(s) of the road beyond 

the FMP Approved Road would remain in place 

July 2013 Page 53




6.0 POTENTIAL EFFECTS AND MITIGATION MEASURES 

As noted in Section 5, mitigation measures have been integrated directly into the Project execution 

plan. These mitigation measures are generally summarized in Table 2-2 and also in the bullets 

below for convenience. 

Adhere to best practices outlined in the well-proven DFO and MNR guidance documents 

referenced herein, as well as AOC prescriptions in the FMP, to avoid causing negative 

environmental effects. 

Harvest timber and construct the road during winter months when outfitters are not active, 

migratory birds are not present and caribou are not utilizing calving grounds. 

Primarily utilize the road during times of year when local outfitters are traditionally not active, 

consistent with precedents in the Trout Lake FMP. 

Identify and avoid biological, archaeological and cultural-heritage values in the vicinity of the 

Project footprint. 

Minimize new developments and cumulative effects in the region by following existing / 

planned roads and historic mineral exploration trails to the extent practical. Decommission 

historic mineral exploration trails that are no longer required for use. 

Follow the 2011 wildfire area to the extent practical to minimize impacts to the viewscape 

and remoteness values. 

Follow GCU’s Spill Emergency Plan and best practices related to management of petroleum 

products. 

Restrict public access via a modern, monitored gate so that the Project does not create 

more public access than what is approved in the FMP. 

Support MNR fire-fighting operations in the vicinity of the Property, abide by Forest Fires 

Prevention Act, monitor for fires and report to MNR as appropriate. 

6.1 Potential Negative Effects Requiring Additional Mitigation Measures 

GCU has undertaken an assessment of the effects associated with the Project in accordance with 

Section 3 of MNR (2003) and these are summarized in Table 2-2. All effects that were assessed in 

Table 2-2 as a negative effect are included in Table 6-1 for specific, supplemental mitigation 

measures beyond those that have been integrated directly into the Project execution plan provided 

in Section 5. 

GCU intends to make best efforts to reasonably mitigate the concerns that are within GCU’s ability 

to mitigate, whether within the scope of this EA process or not. Accordingly, GCU tracks issues 

regarding all its activities related to the Springpole Gold Project to facilitate efficient management 

and mitigation of issues and concerns that arise due to GCU’s activities. The current issues 

management matrix with mitigation measures is presented in Table 3-2. 

Table 6-1 below summarizes the supplemental mitigation measures for potentially significant 

negative effects (refer to Definition of Terms and Acronyms). Potentially significant negative effects 

are defined as the negative effects identified in Table 2-2. Conventional criteria for assessing 

significance of residual negative effects (refer to Definition of Terms) are provided in Section 7. 

July 2013 Page 54




Table 6-1: Supplemental Mitigation Measures for Potentially Significant Negative Residual Effects 

Potentially Significant Negative Residual 

Effect (1) Mitigation Measure Implementation Strategy 

Species at Risk or Their Habitat 

Recovery of a species under special 

management 

Access to trails or inaccessible areas (and 

water) 

Fish or other aquatic species, 

communities or their habitat (including 

movement of resident or migratory 

species) 

Views or aesthetics (Birch River bridge) 

Community character, enjoyment of property 

or local amenities 

Adjacent or nearby uses, persons or property 

Decommission historic exploration trails at the Property, as generally shown in Figure 2-1. 

Support the implementation of specific silvicultural practices in approved areas to improve and create caribou habitat 

elsewhere in the range or proximal ranges. 

Pending guidance from MNR, install educational signage elsewhere within in the range (where there is public access) 

that is intended to help hunters distinguish between caribou and other ungulates. 

Fund and/or participate in monitoring initiatives intended to improve the understanding and management of caribou in 

the province. This focused caribou monitoring is proposed to be carried out in collaboration with MNR and/or any other 

interested parties. 

Prohibit public access beyond the FMP Approved Road, focus usage during winter months, enforce 50 km/hr speed 

limit. 

No increased public access to the region is proposed as part of this Project. Pending agreement of MNR and issuance 

of a Land User Permit, GCU proposes to install a modern, monitored gate at the end of the current FMP road when 

GCU’s road is constructed. When Domtar builds the Wenasaga Road extension that is approved in the 2014-2019 

timeline, GCU proposes to move the gate to the end of the FMP-approved road, which is ~1km south of the Birch River 

crossing (refer to Figure 2-1). In collaboration with MNR and pursuant to the Public Lands Act, GCU proposes to also 

post the names of the additional lakes that may not be accessed on the existing sign at the Tarpley / Wenasaga Road 

junction. 

Although this is less ideal from an engineering and cost perspective, the proposed bridge alignment and approaches 

have been relocated further downstream to minimize impacts to the viewscape from the upstream direction. Refer to 

Section 6.3 for a further description of this mitigation measure. 

Perform construction during the autumn-winter-spring window, when remote tourism operators and local landowners 

are not present. Utilize the road during this same window to the extent practical in an effort to avoid generating noise 

while these stakeholders are present in the region. 

GCU has engaged an independent professional recommended by the office of the Mining and Lands Commissioner to 

serve as an independent arbitrator to facilitate the government's dispute resolution process. The recommended 

process for assessing compensation is provided in Appendix 6. GCU’s views are further described in Section 6.2. 

Maintain an open-door policy to receive concerns so that these can be addressed in a timely manner. 

Noise levels Maintain an open-door policy to receive concerns so that these can be addressed in a timely manner. 

Tourism Values (loss of remoteness and 

marketability of remote tourism businesses) 

Ecological integrity 

Terrestrial wildlife (including numbers, 

diversity and movement of resident or 


Natural vegetation and terrestrial habitat 

linkages or corridors through fragmentation, 

alteration and/or critical loss. 

Water quality or quantity 

Sedimentation or erosion 

Fish or other aquatic species, 

communities or their habitat… 

Includes all negative effects from Table 2-2. 

(1) 

GCU has engaged an independent professional recommended by the office of the Mining and Lands Commissioner to 

serve as an arbitrator to facilitate the government's dispute resolution process. The recommended process for 

assessing compensation is provided in Appendix 6. GCU’s views are further described in Section 6.2. 

The access corridor has been designed to minimize cumulative impacts with other activities to the ecological integrity of 

the region. 

The access corridor has been designed to minimize habitat fragmentation, to avoid biological values to the extent 

practical and respect AOCs that are approved in the FMP. 

Refer to Section 6.4 for additional discussion. 

Adhere to Environmental Guidelines for Access Roads and Water Crossings (MNR, 1995), Crown Land Bridge 

Management Guidelines (MNR, 2008), MNR Guidelines for Culverts Installed in the Winter (MNR, 1996) and Department of 

Fisheries and Oceans Operational Statement for Clear Span Bridges. 

Integrate these mitigation measures into the Project execution plan 

(Section 5). Continue to engage other parties regarding collaborations 

related to monitoring and other measures to achieve a net overall 

benefit. DST (2012) provides further analysis and discussion. 

Potential overall benefit measures related to caribou are further 

described in Appendix 10. The overall benefit measures would be 

formalized in an Overall Benefit permit that is issued for the 

Project following the conclusion of the EA (Section 3.4). 

Integrate this into the final ESR and Project execution plan (Section 5). 

While GCU would have no enforcement authority, GCU is willing to 

collaborate with MNR regarding the monitoring of the corridor and 

reporting of any illegal use to MNR. It is envisioned that GCU’s 

obligations related to monitoring and reporting would be formalized in an 

issued approval that is in accordance with MNR policy. 

The bridge re-alignment is reflected in Appendix 7. 

Integrate this approach directly into the Project execution plan 

(Section 5). Further engagement regarding specific timing windows is 

planned and shall be identified in the final ESR. 

GCU is willing to fund this process and adhere to the 

recommendation for the life of the Springpole Gold definition project 

while the road is in place and being used actively by GCU. 

GCU’s Manager of Community Relations and Lands is contact person 


GCU’s Manager of Community Relations and Lands is contact person 


GCU is willing to fund this process and adhere to the 

recommendation for the life of the Springpole Gold Project while the 

road is being used actively by GCU. 

Integrate into Project execution plan (Section 5). 

Integrated into Project execution plan in Section 5 and monitoring in 

Section 8. 

July 2013 Page 55




6.2 Process to Determine Compensation for Proximal Tourism Operators 

In response to GCU’s Base Case Project Description Report, several proximal tourism operators 

have told GCU that the Project will have a devastating effect on their respective businesses. It is 

acknowledged that proximal tourism operators in the region may be affected by the Project due to 

the further loss of remoteness values. It is also recognized that there may be a reduced marketability 

of these businesses due to the on-going forestry operations and ancillary aggregate resource 

extraction in the area, the 2011 wildfire (refer to Figure 2-1), mineral exploration activities by other 

companies, more distant hydropower developments to the south and the on-going practice of 

traditional activities by members of Aboriginal communities and any related trail development. 

As evidenced by a variety of policies and legislation, the provincial government is interested in a 

prosperous tourism industry as well as a prosperous mineral development industry. It is also 

recognized that the provincial government may currently have limited resources to resolve disputes 

between competing interests in the Crown resources. As a result of these realities and consistent 

with the provisions of the recently modernized Mining Act, GCU has sought a recommendation from 

the office of the Mining and Lands Commissioner for an independent, qualified professional to 

recommend a solution for this particular situation. GCU has engaged this government-endorsed, 

independent professional and obtained a preliminary recommendation regarding the issue of 

compensation. The recommended solution is provided in Appendix 6 and is regarded as being 

consistent with current government policies as well as precedents in similar situations. Obtaining a 

recommendation from this government-endorsed, independent professional is not to be construed 

as a unilateral selection of an arbitrator to determine appropriate compensation for impacts arising 

from this Project. Rather, this measure is intended to be a way to facilitate MNR’s dispute resolution 

process described in MNR (2003) in a timely manner that is consistent with government legislation, 

policy and priorities. 

GCU wishes to be proactive regarding this matter rather than the alternative of doing nothing and 

forcing the affected tourism operators to file a statement of claim against GCU in court for damages. 

Pending any regulatory approvals, entering into a non-binding dispute resolution process that is 

conducted by a qualified, government-endorsed independent party is a measure that GCU’s Board 

and shareholders can support. GCU regards its willingness to implement this recommendation as a 

demonstration of its reasonableness, its commitment to good faith consultation and its desire to 

develop a respectful relationship with local tourism operators. 

6.3 Viewscape at Birch River Crossing 

The proposed Birch River crossing is located at the southeast end of Springpole Lake and is shown 

on Figure 2-1. The viewscape at the proposed Birch River crossing is of particular value to Pickerel 

Arm Camps. Although less ideal from an engineering and cost perspective, the proposed crossing 

location has been modified from the original Base Case Project Description Report to minimize the 

impact to guests at Pickerel Arm Camps. As indicated in Photograph 6-1 the revised crossing 

location will not normally be visible to guests at Pickerel Arm Camps that are fishing on Springpole 

Lake. 

July 2013 Page 56




Photograph 6-1: Modified Alignment of Birch River Bridge 

Towards Pickerel Arm Camps 

6.4 Habitat Fragmentation 

In accordance with section 3 of MNR (2003), habitat fragmentation is considered in Table 7-1 and 7- 

2 under the screening criterion Natural vegetation and terrestrial habitat linkages or corridors 

through fragmentation, alteration and/or critical loss. In Table 7-2, this criterion has been screened 

as low negative effect but further context is provided in this section. The potential impacts to caribou 

habitat are considered separately and are discussed in Appendices 4 and 10. 

The proposed access corridor would provide access to a resource definition project and timber 

harvesting project on private land. This undertaking may have a fragmentation effect of breaking up 

contiguous blocks of habitat. The timber harvesting that is a part of this Project will create a 

landscape of both mature and regenerating stands. From a wildlife habitat perspective this will 

create young stands that favour certain species and older stands that favour other species and it is 

recognized that harvesting and regeneration creates changing habitats. This concept is a complex 

issue with no universally accepted solutions. The MNR in a technical report entitled Landscape 

Analysis for Forest Management Planning in Boreal Northeastern Ontario state that “…our 

understanding of how landscape composition and configuration affect ecosystem processes, 

biodiversity and sustainability is still largely incomplete” (Bridge et al, 2000). While other research 

cited in this paper also state that forest harvesting and subsequent silvicultural practices can alter 

landscape patterns (Spies et al, 1994; Gustafson and Crow 1996) that has implications for resulting 

biological diversity and ecosystem function (Harris 1984; Rosenburg and Raphael 1986; Gustafson 

and Crow 1994; Weir and Johnson 1998). 

With respect to the Project and this draft ESR, GCU has solely undertaken a comparative analysis 

of two (2) alternative access corridors to evaluate potential environmental effects. Based on the 

analysis herein and as further described in DST (2012), the eastern corridor is regarded as having a 

July 2013 Page 57




lower potential for negative effects compared with the western corridor. This is primarily due to 

synergies of the eastern corridor with the future planned FMP Approved Road. 

7.0 SIGNIFICANCE OF RESIDUAL NEGATIVE EFFECTS 

Significance of residual negative effects, after mitigation measures are applied, is commonly 

considered in the context of its magnitude, geographic extent, duration, frequency, degree of 

reversibility, possibility of occurrence or any combination of these factors. Conventional 

considerations for significance criteria for environmental assessments are defined in Table 7-1, as 

well as a description of the significance level (low, medium and high) for each criterion. As 

presented in Table 7-1, significance in this EA analysis is a gradient of low to high, in general 

accordance with guidance in MNR (2003), section 3.3, page 20. The relevant excerpt from MNR 

(2003) is provided in the bullets below for convenience. 

 

 

 

A “low” net effect would be assigned where there is a high degree of certainty as to the 

effect, and where the effect has minimal significance. 

A “medium” net effect may be based on reasonable certainty, and may be significant in 

combination with other medium and high net effects. 

A “high” net effect may reflect high level of certainty that a significant effect will occur, or a 

low level of certainty about one or more effects and a need for further evaluation and 

exploration of mitigation options. 

Potentially significant negative effects associated with the Project are listed in Table 6-1 along with 

mitigation measures. The significance of these residual effects after mitigation measures are applied 

has been assessed in accordance with Table 7-1 and is described in Table 7-2. Please note, a full 

discussion of potential overall benefit measures related to caribou are presented in Appendices 4 

and 10. The overall benefit measures that are discussed herein would be formalized in an Overall 

Benefit permit that is issued for the Project following the conclusion of the EA (refer to Section 3.4). 

July 2013 Page 58




Level of 

Significance 

Ecological / 

Biophysical 

Table 7-1: Generic Significance Criteria Considerations and Levels of Significance 

Socio-Cultural 

Conventional Significance Criteria Considerations 

Magnitude / 

Geographic Extent 

Duration / 

Frequency 

Likelihood 

of 

Occurrence 

Low 

No meaningful 

adverse 

biophysical 

effects 

No meaningful 

adverse effects to 

socio-economic 

interests 

Magnitude and/or 

geographical extent of 

impact(s) considered to be 

minor, and primarily or solely 

confined to Project site 

Construction 

phase of 

Project, or 

during closure 

phase(s) 

Unlikely to 

Occur 

Medium 

Adverse effects 

involve 

commonplace 

species or 

communities 


would involve 

meaningful 

inconvenience to 

local residents or 

land users 



impact(s) have the potential 

to meaningfully affect offproperty 

residents, lands or 

receiving waters 

Life of Project 

Could 

reasonably 

be expected 

to occur 

High 


involve locally 

or regionally 

important 

species or 

communities 

Adverse effects to 

livelihoods and/or 

property values 



impact(s) expected to 

meaningfully affect offproperty 

residents, lands or 

receiving waters 

Significance criteria considerations are intended to be generally consistent with MNR (2003). 

Extends 

beyond life of 

Project 

Will occur, or 

is likely to 

occur 

July 2013 Page 59 

Reversibility 

Readily reversible 

Can be reversed 

with difficulty 

Not reversible




Potentially Significant Residual Negative Effect from Table 6-1 

Table 7-2: Significance of Residual Negative Effects 

Significance Level for 

Residual Negative Effects (1) Rationale / Comment 

Species at risk or their habitat. 

Recovery of a species under special management. 

High 

As part of the suite of impact mitigation measures for caribou, a full discussion of potential overall benefit 

measures related to caribou are presented in Appendix 10. The overall benefit measures would be formalized 

in an Overall Benefit permit that is issued for the Project following the conclusion of the EA (refer to Section 

3.4). Although the residual negative effects are still regarded as having a high significance, the Overall Benefit 

measures will be intended to achieve a net overall benefit for the species in accordance with MNR requirements. 

Access to trails or inaccessible areas (and water). 

Fish or other aquatic species, communities or their habitat (including movement of 

resident or migratory species). 

Low 

Mitigation measures from Section 6 are anticipated to reduce residual negative effects to significance ranking of 

low. 

Views or aesthetics. Low 


low. 

Community character, enjoyment of property or local amenities. 

Adjacent or nearby uses, persons or property. 

Low 


low. 

Noise levels. Low 


low. 

Tourism Values. 

Impacts on businesses and personal lives…due to loss of remoteness values. 

Low 


low. 

Ecological integrity. 

Terrestrial wildlife (including numbers, diversity and movement of resident or 

migratory species). 

Low 


low. 

Natural vegetation and terrestrial habitat linkages or corridors through fragmentation, 

alteration and/or critical loss. 

Water quality or quantity. 

Sedimentation or erosion. 

Low 


low. 

Fish or other aquatic species, communities or their habitat… 

(1) 

The significance level for each negative residual effect shown in Table 7-2 is the highest significance level classification of the significance criteria consideration identified in Table 7-1. 

July 2013 Page 60




8.0 MONITORING AND IMPLEMENTATION 

An audit system will be implemented to verify effective implementation for the mitigation measures 

described herein and in issued approvals. To facilitate compliance management, GCU has 

adequate staff to audit the activities of GCU and its contractors. Non-compliance will be reported to 

the Springpole Gold Project Management team for prompt corrective action. 

Due to the simple, routine nature of the Project mitigation measures, as well as the availability of 

qualified personnel and contractors to carry out the Project, GCU has not developed a specific 

monitoring program for the Project. GCU proposes to follow monitoring and audit programs that are 

utilized for forestry sector road building and timber harvesting operations. 

The Project is the equivalent of a forest access road to a mining project site on the Trout Lake SFL 

requiring harvesting of trees, road construction and stream crossings. Therefore, the Acts, 

regulations, and policies that govern forestry activities on SFL’s in Ontario will be applied. As a 

result, monitoring and auditing will follow the Forest Operations Inspection Program (“FOIP”). GCU 

will adhere to operational winter road standards, stream crossing installation standards and AOC 

operational prescriptions approved in the Trout Lake FMP and applicable Annual Work Schedule 

(“AWS”). 

Upon completion of the harvest, road construction and each stream crossing a forest operations 

compliance report will be completed by a certified forest operations compliance inspector and 

submitted through the FOIP on the Trout Lake SFL. 

GCU will retain a Registered Professional Forester experienced in road building to oversee 

construction of the road. The monitoring of the environmental protection standards will be based on 

the approved Trout Lake Forest Compliance Plan and Forest Compliance Handbook and will be 

reported via the Forest Operations Information Program (“FOIP”) by a certified compliance 

inspector. 

8.1 Routine Monitoring 

GCU anticipates monitoring program requirements in the eventual approvals that are issued for the 

Project. 

8.1.1 Timber Harvesting and Water Crossings 

The road would be monitored in accordance with MNR requirements in Environmental Guidelines for 

Access Roads and Water Crossings (MNR, 1995) and the issued approvals. Water crossings would 

be monitored for signs of erosion or physical instability on a monthly basis and at an increased 

frequency during high flow periods. 

GCU will use the standards outlined in the approved Trout Lake FMP and AWS as the required 

standards for all harvesting and access activities (harvest, access, aggregate, stream crossings). 

The monitoring of these standards will be based on the approved Trout Lake Forest Compliance 

Plan and Forest Compliance Handbook and will be reported via the Forest Operations Information 

Program (“FOIP”). GCU has made a commitment to Domtar to ensure all activities adhere to these 

standards and Domtar’s proposed FSC operations program. 

July 2013 Page 61




8.1.2 Species at Risk Monitoring 

SAR monitoring would be carried out in accordance with MNR requirements that are contained in 

issued approvals and any legislative requirements. Appendix 10 outlines potential Overall Benefit 

activities related to caribou, including monitoring. This monitoring program would be formalized in an 

Overall Benefit permit that is issued for the Project following the conclusion of the EA (refer to 

Section 3.4). 

GCU is currently engaging potentially interested parties regarding collaborative SAR monitoring. 

8.2 Triggered Monitoring 

In accordance with GCU’s Fuel Spill Emergency Plan, an accidental release from a delivery vehicle 

will trigger monitoring of local soil and water quality to ensure the site of the accidental release is 

remediated in accordance with MOE (2009) criteria. Such an incident would also trigger the 

preparation of a remediation report and a review of the incident to prevent a recurrence, in 

accordance with GCU’s Fuel Spill Emergency Plan. 

Water crossings would be monitored for signs of erosion or physical instability on a monthly basis 

and at an increased frequency during spring melt and periods of high rain and/or runoff. 

A public complaint related to the Project would trigger an appropriate monitoring campaign to 

determine the source of the complaint and the need for remedial action. Furthermore, the complaint 

would be reported forthwith to government if required by legislation and site specific approvals. 

9.0 CLOSING REMARKS 

GCU maintains an open-door policy and welcomes feedback regarding all aspects and potential 

future phases of the on-going Springpole Gold Project. GCU’s primary contact person is identified in 

Section 1. It is hoped that an open-door policy will help identify potential impacts and concerns so 

that GCU can address these in a proactive manner. 

GCU intends to keep all stakeholders up to date regarding the Springpole Gold Project and its ongoing 

economic evaluation. In the event that GCU proposes to advance the Springpole Gold Project 

beyond the Project and on-going preliminary exploration activity that is described in this Report, an 

entirely new provincial EA, consultation and approvals process will be required. A decision to initiate 

an EA process for development of a mineral deposit may be triggered by a positive economic 

evaluation, market conditions, commodity prices, financing requirements or simply a proponent’s 

confidence in the robustness of a mineral deposit. 

Due to the proposed winter construction window to avoid the tourism operator’s active season, the 

caribou calving season and to avoid impacts to migratory birds, GCU regards this Project as 

providing tangible environmental and social benefits compared with the execution of this work during 

summer months, as is currently approved in the Trout Lake Forest FMP. 

As one of the most significant impact mitigation measures associated with this Project, GCU has 

committed to a winter construction program to mitigate potential impacts to biological values, tourism 

operators and landowners. In addition, GCU has committed to making best efforts to utilizing the 

road during winter months and minimizing road use during summer months. GCU’s proposal to 

July 2013 Page 62




construct a winter operational road provides a natural incentive for GCU to adhere to this 

commitment rather than utilizing slow moving off-road haulage equipment with high operating costs 

during the summer months that can damage the road base and cause both environmental and 

social issues. 

Where there are outstanding concerns about this Project that cannot be resolved in 

discussion with the MNR, concerned parties have an opportunity to formally request the 

Minister of the Environment issue a Part II Order requiring the project be subject to an individual 

environmental assessment under the Environmental Assessment Act. As this decision rests with 

the Minister of the Environment, parties should direct their inquiries in this regard to the Minister of the 

Environment. 

Minister of the Environment 

135 St. Clair Ave. West, 12th Floor 

Toronto, ON M4V 1P5 

Requests must be received by the Minister within the 30-day comment period, which expires on 2 

April 2013, and copied at the same time to the MNR contact person at the address below. 

David New 

Red Lake South Area Supervisor 

Ontario Ministry of Natural Resources 

P.O. Box 5003 

Red Lake, ON P0V 2M0 

Phone: 807-727-1383 

Fax: 807-727-2861 

Email: dave.new@ontario.ca 

10.0 PATH FORWARD FOR SPRINGPOLE GOLD PROJECT 

The outreach program for this Project has raised a variety of comments regarding future potential 

development, production and closure phases of the Springpole Gold Project. Although development 

is not being proposed at this time, GCU shall prepare a Project Description for these future potential 

phases in order to begin soliciting comments and developing mitigation measures for any concerns 

associated these potential future phases of the Springpole Gold Project. As well, GCU wishes to 

identify mutually beneficial opportunities with the Aboriginal communities, the local tourism 

operators, other interested stakeholders and GCU believes that a collaborative review of the future 

potential phases of the Springpole Gold Project would facilitate these opportunities. 

GCU wishes to create a lasting positive legacy in regions where it operates and shall seek 

opportunities to strengthen the communities, infrastructure and businesses in these regions. As well, 

GCU recognizes that mining is an interim land use and fully believes that the impacts associated 

with active periods of a mineral development project can be effectively mitigated such that there is a 

net benefit prior to returning the land to a productive, aesthetically pleasing and ecologically 

functional land use upon closure. 

July 2013 Page 63

APPENDIX 1 

FIGURES

APPENDIX 2 

LETTERS FROM HORIZON 

ARCHAEOLOGY

APPENDIX 3 

PUBLIC STAKEHOLDER 

REGISTRY

Round 1 Consultation - Early pre-consultation, emails, calls/meetings. 

Aboriginal consultation: 

Cat Lake First Nation 

Slate Falls First Nation 

Lac Seul First Nation 

Wabauskang First Nation 

Métis Nation of Ontario 

Public consultation: 

List provided by MNR: 

Company 

Pickerel Arm Camps 

KaBeeLo Lodge 

Lac Seul Airways 

Fort Francis Northern Wilderness Outfitters 

Birch Lake Lodge 

KayAir Service 

Hidden Bay Lodge 

True North Outpost and Camps 

Green Airways 

Best Baits 

Whitewing Floating Lodges 

D & E Minnows 

added in late April as per MNR 

added in late April as per MNR 

Comments 

removed; no longer own outpost at Springpole Lake 

Added by GCU: 

Private cabin owner, Springpole Lake 

Private cabin owner, Birch Lake 

Red Pine Lodge 

Kenora District Campowners Association

Final ESR consultation list.xls 

Round 2 Consultation - Mail-out notification list, follow-up calls, meetings as requested 

Company 

Comment\ 

Department of Fisheries & Oceans 

Domtar Pulp and Paper Products Inc. 

Douglas Bay Camp 

dropped as per MNR; camp and contact not located 

Ear Falls Contracting Ltd. 

Ear Falls Hunters & Anglers 

Ear Falls Trappers Council 

Federation of Naturalists 

Hydro One 

Ministry of Citizen, Culture, Tourism & Recreation Contact info updated to Min. of Tourism Culture and Sport 

Ministry of Culture and Recreation 

Contact info updated to Min. of Tourism Culture and Sport 

Ministry of Labour 

Ministry of Northern Development & Mines 

Ministry of the Environment 

x2 

Municipality of Red Lake 

Native Trapper's Council 

Nishnabe Aski Nation 

North Lake Lodge removed at request of owner; located west of Hwy 105 

Northwest Métis Nation of Ontario Council 

- added Métis Nation of Ontario Region One Consultation Branch 

Northwestern Ontario Prospectors Association 

Northwestern Ontario Tourism Association (NWOTA) 

Ontario Baitfish Association 

removed; organization does not exist, could not identify successor 

Ontario Federation of Anglers & Hunters 

Ontario Ministry Aboriginal Affairs 

Red Lake Trapper's Council 

Township of Ear Falls 

Grand Council Treaty #3 

Windigo Tribal Council (CLFN, SFFN) 

Bimose Tribal Council (WFN) 

Independent First Nation Alliance (LSFN) 

Aboriginal and Northern Development Canada 

Wildland League 

Greenpeace 

Forest Ethics 

removed as per MNR; contact unreachable 

Earthroots 

Ontario Natura 

Additions from MNR during the Consultation process 

Private cabin owner, Birch Lake 

Trapline owner (SL196) 

Trapline owner (Springpole Lake) 

* there are 7 additional trapline owners contacted by MNR, due to Protection of Privacy Policy 

Latrille Lake Lodge 

Page 1

APPENDIX 4 

BIOLOGICAL CONSTRAINTS 

REPORT FOR SPRINGPOLE GOLD 

ACCESS CORRIDOR PROJECT 

ALTERNATIVES ASSESSMENT 

(DST, 2013A)

GOLD CANYON RESOURCES 

SPRINGPOLE GOLD PROJECT 

BIOLOGICAL CONSTRAINTS REPORT FOR SPRINGPOLE 

GOLD ACCESS CORRIDOR PROJECT ALTERNATIVES 

ASSESSMENT 

Gold Canyon Resources 


P.O. Box 10356 Pacific Centre 

Vancouver, BC., V7Y 1G5 

July 2013 

DST File No.: OE-KN-014468 

DST Consulting Engineers Inc. 

106 Cumberland St. N., Suite 100, Thunder Bay, Ontario P7A 4M2 

Tel.: (807) 345-3620 Fax: (807) 344-4738 E-mail: thunderbay@dstgroup.com


Springpole Gold Project 

Road Alternatives Assessment 

Table of Contents 

1.0 Introduction ..................................................................................................................... 6 

Project Understanding ............................................................................................................ 6 

Objectives .............................................................................................................................. 7 

Methodology........................................................................................................................... 7 

Assessment Boundaries......................................................................................................... 9 

2.0 Description of the Existing Environment .........................................................................11 

Terrestrial Environment .........................................................................................................11 

Migratory Birds ......................................................................................................................14 

Moose ...................................................................................................................................27 

Large Mammals and Furbearers............................................................................................30 

Species at Risk – Woodland Caribou ....................................................................................33 

Species at Risk - Wolverine...................................................................................................36 

Significant Wildlife Habitat .....................................................................................................36 

Habitats of Seasonal Concentrations of Animals ...................................................................37 

Aquatics ................................................................................................................................47 

3.0 Environmental Effects Analysis ......................................................................................51 

Terrestrial Environment .........................................................................................................51 

Environmental Effects ........................................................................................................51 

Mitigation ...........................................................................................................................51 

Significance .......................................................................................................................52 

Comparison of effects ........................................................................................................52 

Migratory Birds ......................................................................................................................56 


Mitigation ...........................................................................................................................57 

Significance .......................................................................................................................57 


Moose ...................................................................................................................................58 


Mitigation ...........................................................................................................................58 

Significance .......................................................................................................................58 

Comparison of effects ........................................................................................................59




Large Mammals and Furbearers............................................................................................61 


Mitigation ...........................................................................................................................61 

Significance .......................................................................................................................61 


Woodland Caribou.................................................................................................................61 

Environmental Effects and Mitigation .................................................................................63 

Significance .......................................................................................................................75 

Comparison of Effects........................................................................................................75 

Wolverine ..............................................................................................................................78 


Mitigation ...........................................................................................................................78 

Significance .......................................................................................................................78 

Significant Wildlife Habitat .....................................................................................................78 


Habitats of Seasonal Concentrations of Animals................................................................78 

Rare Vegetation Communities or Specialized Habitats for Wildlife.....................................80 

Habitats of Species of Conservation Concern ....................................................................80 

Aquatic Resources ................................................................................................................82 


Mitigation ...........................................................................................................................83 

Significance .......................................................................................................................83




List of Figures: 

Figure 1.1 Proposed Road Corridor Options .............................................................................. 8 

Figure 1.2 Regional and Local Study Areas in the Springpole Lake Area..................................10 

Figure 2.1 Regional Study area and Wabigoon Ecoregion ........................................................13 

Figure 2.2 Probability of Habitat Occupancy for Alder Flycatcher..............................................15 

Figure 2.3 Probability of Habitat Occupancy for Bay-breasted Warbler .....................................16 

Figure 2.4 Probability of Habitat Occupancy for Blackburnian Warbler......................................17 

Figure 2.5 Probability of Habitat Occupancy for Brown Creeper................................................18 

Figure 2.6 Probability of Habitat Occupancy for Chestnut-sided Warbler ..................................19 

Figure 2.7 Probability of Habitat Occupancy for Common Yellowthroat.....................................20 

Figure 2.8 Probability of Habitat Occupancy for Least Flycatcher .............................................21 

Figure 2.9 Probability of Habitat Occupancy for Ovenbird .........................................................22 

Figure 2.10 Probability of Habitat Occupancy for Red-breasted Nuthatch.................................23 

Figure 2.11 Probability of Habitat Occupancy for Red-eyed Vireo.............................................24 

Figure 2.12 Probability of Habitat Occupancy for Winter Wren..................................................25 

Figure 2.13 Aerial Survey of Springpole Lake 2011 ..................................................................29 

Figure 2.14 Location of RSA within Churchill Caribou Range....................................................35 

Figure 2.15 Late Winter Moose Habitat.....................................................................................39 

Figure 2.16 Waterfowl Survey Locations and Colonial Bird Nesting Sites .................................40 

Figure 2.17 Old Growth Stands.................................................................................................42 

Figure 2.18 Raptor Nesting Locations .......................................................................................45 

Figure 2.19 Moose Aquatic Feeding Areas ...............................................................................46 

Figure 2.20 Thermal Designations of Lakes in the Springpole Area ..........................................50 

Figure 3.1 Predicted Moose Densities.......................................................................................60 

Figure 3.2 Winter Caribou Patches within the Springpole Lake Project .....................................70




List of Tables: 

Table 3.1.1 Provincial Ecosite and Forest Unit definitions within the Trout Lake Forest that have 

the potential to be affected by the Project .................................................................................53 

Table 3.1.2 Number of polygons (count), total area (ha) and percentage of total area of ecosites 

found in the Trout Lake Forest ..................................................................................................54 

Table 3.1.3 Total area of ecosites potentially affected (ha) and percent of total ecosite area 

potentially affected by each road option in the Springpole study area .......................................55 

Table 3.1.4 Total area (ha) and percentage of total area of forest units found in the Trout Lake 

Forest .......................................................................................................................................55 

Table 3.1.5 Potential area of Forest units (ha) and percent of total forest unit areas potentially 

affected by each road option in the Springpole study area ........................................................56 

Table 3.2.1 Amount (ha) of song bird breeding habitat that would be affected by each road 

corridor option...........................................................................................................................57 

Table 4.2.20 Comparison of disturbance statistics between road options A and B for the 

Churchill Caribou Range. ..........................................................................................................67 

Table 4.2.3 Comparison of habitat statistics between road options A and B for the Churchill 

Caribou Range..........................................................................................................................68 

Table 4.2.4 Total area (ha) of caribou winter habitat patches potentially affected by each road 

corridor option...........................................................................................................................69 

Table 4.2.5 Total area of caribou winter habitat patches within the Trout Lake Forest and the 

RSA pre-, and post-2011 wildfire...............................................................................................69 

Table 4.2.6 Percent of total area of caribou winter habitat patches within the Trout Lake Forest 

and the RSA pre-, and post-2011 wildfire..................................................................................69 

Table 4.2.7 Comparison of nursery/calving statistics between road options A and B for the 

Churchill Caribou Range. ..........................................................................................................74 

Table 3.4.7 Comparison of road corridor options in the Springpole Lake area with regard to 

environmental effects to caribou ...............................................................................................77 

Table 3.6.1 Provincially rare (S1, S2, S3) species with the potential to occur in the Springpole 

area (from the Significant Wildlife Habitat Technical Guide OMNR 2000) .................................81




1.0 Introduction 

Gold Canyon Resources Inc. (GCU) is a growing mineral exploration company which holds a 

100% interest in the large Springpole Gold Project (the Project), situated in the prolific Red Lake 

Mining District of northwestern Ontario. The Springpole Property is comprised of mining patents 

and mining claims. GCU holds the mineral rights to the entire Property, which extends from the 

north end of Springpole Lake and connects to the end of the current Wenasaga Road. The 

Property has been explored intermittently for gold since the 1920s. GCU obtained the Property 

in 1998 and has explored the Property and expanded its land position since that time. 

GCU is seeking to develop improved access to the Property and, ultimately an access corridor 

for year-round use. 

GCU has conducted an alternatives assessment regarding the potential access corridors. The 

preferred alternative (Option A) utilizes and expands on existing and planned forestry roads in 

the region as well as existing exploration roads, in order to minimize the potential for cumulative 

effects. This approach is described in Section 5. GCU is currently engaging 

The Project triggered the requirement for a Class EA pursuant to MNR’s A Class Environmental 

Assessment for MNR Resource Stewardship and Facility Development Projects (2003), due to 

the proposed disposition of Crown resources. This Report has been prepared to comply with 

requirements of the MNR (2003) and to follow current best practices regarding environmental 

assessment. 

Project Understanding 

The Project comprises the development of a restricted use access corridor (~15 m in width) in 

accordance with accepted best practices to minimize effects to fish and wildlife values, 

archaeological values and Aboriginal community sensitive sites (Figure 1.1). 

The preferred access corridor (Option A) follows the planned Wenasaga Road corridor 

(approved for construction in 2014 in the Trout Lake Forest Management Plan) and portions of 

pre-existing mineral exploration trails that extend from the GCU camp at the north end of 

Springpole Lake eastward. These historic exploration trails exist due to the long history of 

exploration at the property. It is GCU’s intent to eventually remove these historic exploration 

trails from use where practical and rehabilitate them. 

The entire length of the preferred corridor option (Option A) beyond the Forest Management 

Plan (FMP) approved corridor is situated within GCU claims, however, only a portion of Option 

B is located within the claims boundary (Figure 1.1). Highway vehicles, as well as off-road 

equipment, would be utilized to import and export materials, equipment and personnel from the 

Project site. DST understands that GCU continues to consult and engage stakeholders 

regarding the standard of the road that is proposed within the corridor, as well as the use 

strategy for the corridor. Furthermore, DST understands that details will be provided in GCU’s 

Environmental Study Report that is being prepared for MNR.




GCU has taken known proposed road corridors into consideration while planning their access 

corridor. The existing Wenasaga road was extended from the Monkman Road to the southeast 

corner of Dead Dog Lake during the 2009 Forest Management Plan (FMP). This corridor is 

expected to be progressively extended to the northeast corner of the Trout Lake Forest 

(northeast of Springpole Lake) to allow access to caribou mosaic blocks. The 2009-2019 Trout 

Lake FMP states that the extension of the Wenasaga road “is necessary to complete access of 

the Caribou Mosaic Block A-8 and develop access into Block B-3. It is imperative that this road 

be built in the 2009-2019 plan period to access wood in the far northeast corner of the license.” 

The extension of the Wenasaga road north of Springpole Lake is also necessary in order to 

allow for the construction of the North Polar Road, which will connect the Wenasaga road to the 

Lac Seul Forest in the east. This will provide the only access to the northern portion of the Lac 

Seul Forest and according to the Trout Lake FMP Supplementary Documentation 23, “…this is 

the only access route available”. 

Objectives 

The overall objective of this report is to compare the biological factors surrounding the 2 

identified alternative road corridors and highlight the potential constraints associated with each 

alternative. This report will focus on a detailed desktop analysis of the natural environment of 

the study area in conjunction with data gathered through field studies, in order to draw 

conclusions regarding a preferred corridor alternative. 

Methodology 

An aerial investigation of both potential corridors was conducted on February 7 th and 8 th 2012, in 

order to determine wildlife values, assess water crossings and to gain an understanding of the 

overall scope of the potentially impacted area. 

To properly characterize the natural environment of the study area for the alternatives 

assessment, a number of data sources were consulted including; environmental baseline data 

collected in 2011/2012, correspondence with Red Lake MNR, Natural Heritage Information 

Center (NHIC), Species at Risk Ontario (SARO) database, Ontario Breeding Bird Atlas (OBBA), 

MNR Natural Resources Values Information System, Trout Lake Forest Management Plan, and 

digital Forest Resource Inventory (FRI) data for the Trout Lake forest. FRI data was not 

available for the entire study area. Wildlife habitat modelling for selected species was completed 

through the use of the Ontario Landscape Tool (OLT) for those portions of the study area that 

had FRI data. The OLT uses Landscape Scripting Language, which is a proprietary tool for 

Geographic Information Systems (GIS) developed by the MNR. The OLT relies on forest unit 

information provided through digital FRI data, to develop prescriptive indicators such as conifer 

age class distribution and landscape cover, as well as evaluative indicators of wildlife habitat 

quality and distribution. These evaluative indicators include the spatial identification of wildlife 

habitat for 7 focal wildlife species including; Woodland Caribou (Rangifer tarandus), Moose 

(Alces alces), Marten (Martes americana), Lynx (Lynx canadensis), Snowshoe Hare (Lepus 

americanus), Fisher (Martes pennanti) and Northern Flying Squirrel (Glaucomys sabrinus), as 

well as many species of songbirds.




Assessment Boundaries 

For the purposes of this assessment, the study area has been divided into a Local Study Area 

(LSA) and a Regional Study Area (RSA). For the terrestrial component of this study (e.g. 

wildlife, vegetation etc.), the LSA included the road corridors and the areas immediately 

adjacent to these locations that could be physically impacted by development. The LSA 

extended to 1 km on either side of these areas. The boundaries of the RSA varied depending on 

the component being studied. For example, the wildlife RSA extended approximately 25 km 

from either side of the road corridors, whereas the vegetation RSA extended 5 km on either side 

of the road corridors (Figure 1.2). 

The wildlife RSA was delineated to take into account the movement of species with large home 

ranges such as caribou and wolverine, as well as to capture rare or sensitive species that could 

potentially occur in the area. The wildlife RSA does not extend 25 km north of the site due to the 

fact that no FRI data exists for this area, making any spatial analysis impossible.




2.0 Description of the Existing Environment 

Terrestrial Environment 

The Springpole Lake RSA lies within the Trout Lake Forest Management Unit (FMU) in 

northwestern Ontario. The Trout Lake FMU falls within the boundaries of the Wabigoon 

Ecoregion (Figure 2.1). The area is located on the Precambrian Shield and the bedrock in the 

area is primarily granitic and gneissic. The landscape of the ecoregion is a gently sloping plain 

of shallow sandy and loamy tills over bedrock in conjunction with eskers and moraine ridges. 

Coniferous cover dominates the landscape (30%) in addition to sparse forest (23.5%), water 

(14.8 %), mixed forest (10.2 %), and treed bogs (4.3 %). Due to shallow substrates and 

periodically dry climate, the area is subjected to intense and frequent fire cycles. Upland 

coniferous fires cycles range from 50 to 187 years and tend to be stand replacing. Mixed stand 

fire cycles tend to occur between 63 and 210 years with variable intensities (Crins et al 2009). 

The Wabigoon Ecoregion is located in Rowe’s (1972) Northern Coniferous Forest Section of the 

Boreal Forest Region. Upland sites tend to be occupied by jack pine (Pinus banksiana) and 

black spruce (Picea mariana), with mixtures of white spruce (Picea glauca) and balsam fir 

(Abies balsamea), depending on stand age. Dry sites often support open jack pine lichen 

complexes, which are an integral component of woodland caribou habitat. White birch (Betula 

papyrifera) or trembling aspen (Populus tremuloides) can be found in conifer dominated mixedwood 

stands. Lowlands are comprised of bog or fen complexes, while treed lowlands are 

dominated by black spruce or tamarack (Larix laricinea) (Crins et al 2009). 

The Trout Lake FMU is located within the Red Lake District, in the Ontario Ministry of Natural 

Resources (OMNR) Northwest Region. Domtar Pulp and Paper Products Inc. is the Sustainable 

Forest License (SFL) holder and as such, are responsible for all forest management planning, 

harvesting, reforestation and monitoring within the FMU. Two provincial parks occur adjacent to 

or within the Trout Lake Forest including Pakwash Provincial Park, located adjacent to the 

southwest corner of the unit, and Trout Lake Provincial Nature Reserve, located in the 

northwest portion of the unit. The FMU also contains 7 conservation reserves including Trout 

Lake, Gull-Christina, Brokenmouth River, Harth Lake, Bruce Lake, Lac Seul Islands and 

Whitemud. 

The land-base of the Trout Lake Forest has been classified into ecosites according to the 

Terrestrial and Wetland Ecosites of Northwestern Ontario. An ecosite is primarily a mapping unit 

based on a consistent set of soil and vegetative characteristics. Ecosite classification is, in large 

part, done from photo interpretation and the aid of a limited field sub-sample. In 2009 the OMNR 

refined their ecosite concepts with the release of Ecosites of Ontario (OMNR 2009c), which 

replaced previous ecosite classification manuals. Ecosites in the study area have been 

classified using this new Provincial Ecosite classification system (OMNR 2009c). 

Provincial Ecosite B049 is the most common ecosite in the forest (38% of stands). Provincial 

Ecosite B049 is considered dry to fresh, with well drained sandy or coarse loamy soils 

dominated by black spruce and jack pine with limited hardwood cover. Provincial Ecosite B052 

covers 13% of the forest and is characterized by fresh, coarse loamy soil supporting stands




dominated by balsam fir, white spruce and black spruce. Provincial Ecosites B128 and B127 

cover 12% and 8% of the forest respectively. Ecosite B128 is an intermediate swamp, with 

lowland black spruce on organic peat. Ecosite B127 is similar to B128 with the exception of 

being wetter and having shallower organic soils, which lowers the productivity of the site. 

Ecosite B065 can be found in 6% of the stands in this forest and is dominated by black spruce 

and jack pine on coarse loamy soil. Poplar and white birch may also occur on these sites. 

Ecosite B082 (4%) is similar to ecosite B065, except that there is a lower incidence of hardwood 

inclusions and the soil is fine, loamy clayey soil. Ecosite B055 covers 5% of the forest and is 

comprised of fresh, well drained coarse loamy to fine sandy soils. Dominant tree communities 

include trembling aspen, white birch, and balsam fir with occurrences of white spruce and black 

spruce. Ecosites B012 and B034 each occupy 4%. The overstory of both ecosites is comprised 

of jack pine and/or black spruce. Ecosite B034 can have occurrences of white birch due to its 

deeper soils. Ecosite B012 is classified by its very shallow soils of




Migratory Birds 

Avian species richness was found to be relatively low within the RSA, which is typical of 

northern boreal forest sites. A total of 113 individual birds from 25 different species were 

observed during 10 point counts in 2011. Breeding bird surveys were conducted throughout the 

study area and followed the protocol described for the Ontario Breeding Bird Atlas (Cadman et 

al. 2007). Point counts consisted of a ten minute non-fixed radius count during which all bird 

species heard or seen were recorded. Point count locations were distributed to represent the 

range of habitat types found throughout the study area. The same points were surveyed twice, 

once in June and a second time in July. The surveys were undertaken during favorable weather 

conditions, began at sunrise and were completed by 10:00 am. The bird community was 

dominated by warblers and thrushes, which is typical of the boreal forest. The average number 

of birds per point count was 11.3 and the average number of species per point count (average 

species richness) was 7.8. No provincially designated Threatened or Endangered species were 

encountered during the 2011 breeding bird survey, however, an active Bonaparte’s Gull (Larus 

philadelphia) nesting colony was found at one of the point count locations west of the 

Springpole Lake camp. The OMNR considers the nesting colonies of all bird species to be 

significant wildlife habitat (OMNR 2009), and as such they have a list of recommended 

guidelines to follow regarding these features (such as minimum buffer distances for disturbance 

and timing restrictions for construction activities). Yellow-rumped warbler and White-throated 

sparrow were the most abundant species encountered during the surveys. 

Habitat modelling for songbirds was conducted for the Trout Lake Forest and for the Wildlife 

Study Area using the Ontario Landscape Tool (OLT). The OLT relies on forest unit information 

provided through digital FRI data, to develop evaluative indicators of forest health. These 

evaluative indicators include spatial identification of spring breeding habitat for 11 songbird 

species (Alder Flycatcher (Empidonax alnorum), Brown Creeper (Certhia americana), Common 

Yellowthroat (Geothlypis trichas), Chestnut-sided Warbler (Setophaga pensylvanica), Least 

Flycatcher (Empidonax minimus), Ovenbird (Seiurus aurocapillus), Red-breasted Nuthatch 

(Sitta canadensis), Red-eyed Vireo (Vireo olivaceus), Winter Wren (Troglodytes troglodytes), 

Bay-breasted Warbler (Dendroica castanea), and Blackburnian Warbler (Dendroica fusca) 

(Figure 2.2 to 2.12).




Additional breeding bird surveys were carried out in May and June 2012. During these surveys 

a total of 37 point count stations were surveyed once in May and repeated in June. Point count 

surveys followed the same protocol as the 2011 surveys (Cadman et al. 2007). Point count 

surveys do not take into account secretive marsh birds, crepuscular and early-nesting species. 

Specific surveys to target these breeding species were completed in 2012, as recommended by 

EC and described below. Two Northern Ontario nocturnal owl surveys were completed 

according to Ontario Breeding Bird Atlas (OBBA) protocol in April 2012. The survey method 

involves playing a standardized recording and listening for Owl callback. The recording that was 

used consisted of Northern Boreal Owl calls and Barred Owl calls – each with designated play 

times and listening times. The total for each recording and listening session was 6 minutes. 

Protocol suggests that surveys are completed in April as this time of year is when Owls are 

most territorial and most likely to respond to calls. 

Four Marsh Monitoring sites were visited on at 2 occasions in 2012; once in May, and a second 

time in June to target the more secretive species associated with wetland habitats. Marsh 

monitoring points were selected in key habitat areas, located along edges of open water marsh 

wetlands in the study area. Surveys were conducted after 18:00 and completed before sunset. 

The call playback method was used as per the protocol from Bird Studies Canada which 

recommends 5 minutes of silent listening upon arriving at the marsh site followed by 5 minutes 

of call playback. Marsh birds on the playback tape were Least Bittern (Ixobrychus exilis), Sora 

(Porzana carolina), Virginia Rail (Rallus limicola), American Coot (Fulica americana) and Piedbilled 

Grebe (Podilymbus podiceps). After the calls were played a second 5 minute period of 

silent listening was employed. Standardized field data sheets were used to record observed 

species, wetland features and weather conditions. 

Twenty waterfowl surveys were completed at 20 sites across the study area in May of 2012. 

Shorelines and bays on larger lakes were scanned by boat paying extra attention to marsh 

areas. Several smaller lakes and ponds were hiked into and any waterfowl, nests and incidental 

species were recorded. Species, number and social structure were recorded. A second visit to 

each waterfowl survey site was performed in June 2012 to note broods. A total of 76 species 

were detected over the various surveys. 

Twenty-six bird species were noted as probable breeders based on the 2012 surveys. These 

species were classified as probable breeders based on active nest discovery, adults carrying 

food, or two occurrences at a given point count location in both May and June. Species richness 

was the highest in point count stations that were in close proximity to a mix of habitats; 

specifically wetland areas and forests with dense understory. The 10 species encountered most 

frequently during point count surveys in descending order were; White-throated Sparrow 

(Zonotrichia albicollis), Ruby-crowned Kinglet (Regulus calendula), Magnolia Warbler 

(Setophaga magnolia), Nashville Warbler (Oreothlypis ruficapilla), Hermit Thrush (Catharus 

guttatus), Winter Wren (Troglodytes troglodytes), Least Flycatcher (Empidonax minimus), Redbreasted 

Nuthatch (Sitta canadensis), Yellow-rumped Warbler (Setophaga coronata) and Redeyed 

Vireo (Vireo olivaceus).




The only species at risk (SAR) which occurred were Bald Eagle (Haliaeetus leucocephalus) and 

Olive-sided Flycatcher (Contopus cooperi). 

In northwestern Ontario, the Bald Eagle population is provincially designated as Special 

Concern. Two active Bald Eagle nests were observed in the study area. Bald Eagles require an 

extensive breeding area in mature deciduous or mixed woods with super-canopy trees for nest 

sites and hunting perches near large lakes or rivers. 

Olive-sided flycatchers, a species currently designated federally as Threatened and provincially 

as Special Concern, were noted 3 times in 2 different locations. This species prefers semi-open 

conifer edges near water sources, such as lakes, ponds or rivers. They are also found in other 

edge and forest opening situations in coniferous and mixed forests including bogs, burns, 

beaver meadows, and small clear cuts. 

The Canada Warbler prefers large tracts of older lowland mixed and deciduous forest with well 

developed understory. Canada Warbler was not encountered in either the 2011 or 2012 surveys 

but suitable habitat does occur in the study area. The Common Nighthawk (special concern) 

and Eastern Whip-Poor-Will (threatened) both prefer areas with open habitat such as burns, 

cutovers and bogs. This habitat occurs in very limited amount in the area surveyed so it is not 

surprising that neither species were encountered during the surveys, however, there are 

extensively burned areas to the south of the areas surveyed. A flock of Common Nighthawks 

were seen (~15 individuals) on Skingle Lake in August of 2012, as well as one individual sitting 

on a nest with two eggs. Peregrine Falcon and Golden Eagle are both known to occur within the 

boreal forest, but as both species prefer large cliffs for nesting and no large cliffs occur in the 

study area, it is likely that these species would only be observed in the study area during 

migration. The Horned Grebe prefers small, shallow ponds with areas of high interspersion of 

open water and emergent vegetation. Limited habitat occurs in the study area and there is 

limited breeding evidence in the extreme west of the province, so it is unlikely that Horned 

Grebe occurs in the study area. 

Moose 

Moose are the largest living member of the deer family (Cervidae) and can be found throughout 

the boreal forest. The distribution of moose in Canada is limited in the north by suitable food and 

in the south by high ambient temperature. Moose are primarily browsers feeding on woody 

browse re-growth following disturbance. They prefer twigs in winter and leaves of deciduous 

trees in the summer. Aspen, birch and willow (Salix spp.) tend to be eaten in large quantities 

compared to other plant species (Renecker and Schwartz 1998). 

Moose share habitat spatially and temporally with other members of the deer family including 

caribou and white-tailed deer. Interspecific competition can occur between white-tailed deer and 

moose in winter, however, parasite-mediated competition occurs with the presence of a shared 

parasite (meningeal worm) which infects moose and causes neurologic disease. In multi-prey 

systems moose can influence, or be influenced by, the density of other prey species (Anderson 

1965).




Moose move within, and migrate between, seasonal ranges as well as disperse to new ranges. 

Within seasonal ranges, moose establish home ranges which vary from 2 to 92 km 2 . The 

variance in home range size can be attributed to a number of factors including season, 

geography, weather, habitat, sex and age (Hundertmark 1998). 

The necessary components of moose habitat include abundant high-quality winter food, shelter 

near food, isolated calving sites, aquatic feeding areas, seral forest stands with deciduous 

shrubs and forbs in summer, mature forests for shelter from snow and heat, travel corridors, and 

mineral licks (Thompson and Stewart 1998). Moose aquatic feeding areas (MAFAs), as 

previously mentioned, are an integral component of moose habitat. The locations of known 

MAFAs are available from the OMNRs Natural Resource Values Information System (NRVIS). 

There are no known MAFAs in the LSA, but there is one in the RSA located west of Superstition 

and Grace Lakes. The study area is located in Cervid Ecological Zone B of the Cervid 

Ecological Framework (CEF) (OMNR 2009b). This zone has a management focus on woodland 

caribou with low to moderate densities of moose. 

An aerial survey was conducted early February 2011 within a portion of the LSA (Figure 2.13). 

The area surveyed encompassed the claims area held by Gold Canyon Resources Inc. at that 

time and therefore did not cover the entire area being considered within this report. A total of 8 

moose (Alces alces) were seen during the survey (6 cows and 2 calves). The area around 

Springpole Lake was found to have some high quality moose habitat interspersed with large 

areas of medium quality caribou habitat. No bull moose were seen during the ungulate survey. 

This would normally indicate that there could be a moose management issue resulting in a 

skewed sex ratio, however, such a small area was surveyed that population demographic 

conclusions would be irrelevant. All of the moose observed appeared to be in good condition. 

Winter tick (Dermacentor albipictus) did not appear to be an issue with any of the moose 

observed. Only a few moose tracks were seen where no moose were observed, indicating that 

the survey sightability of moose was reasonably high. Although there are some white-tailed deer 

(Odocoileus virginianus) known to occur in the study area, none were seen during the aerial 

survey.




Large Mammals and Furbearers 

There are many species of large mammals and furbearers that can be found within the study 

area, and describing the biology and/or ecology of each of these species would be a significant 

undertaking. For the purposes of this report, the emphasis will be on “significant” species which 

are those species that are used as featured wildlife species for forest management planning and 

species of economic or social importance. Species at risk are discussed as part of their 

respective sections within this report. 

Gray wolves (Canis lupus) are believed to have 5 subspecies in North America: Arctic island 

wolf, Mexican wolf, Algonquin park wolf, Minnesota wolf and Alaskan wolf (Nowak 1995). The 

Minnesota wolf is the subspecies which is found within the study area. Wolves are opportunistic 

feeders, specializing in ungulates such as moose, caribou, white-tailed deer (Odocoileus 

virginianus), and elk (Cervus canadensis). Hares and beaver (Castor canadensis) can also be 

important food items in the diet of some populations of wolves. Where several species of 

ungulates occur in the same area, wolves will show a preference for certain species (Bergerud 

1990). Wolves are capable of moving long distances, with daily movement rates ranging from 

1.6 to 72 km (Burkholder 1959). 

Black bears (Ursus americana) can serve as keystone species which are sometimes used as 

landscape-level indicator species, reflecting changes across large regions. Although black bears 

are classified as carnivores, they are functionally omnivores, consuming a wide variety of plant 

and animal foods. Black bears can be a significant source of ungulate calf mortality. Summer 

food habits generally contain a predominance of soft mast such as blueberry, huckleberry and 

serviceberry. An abundance of nuts or fall berries (cherry, blueberry) is vital to the survival of 

black bears because they live off of fat stores while hibernating for 2 to 5 months. Black bears 

move in response to seasonal availability of food, to facilitate dispersal as subadults, to pursue 

breeding opportunities, and before and after denning (Rogers 1977). The habitat requirements 

of black bears vary and can include mixedwoods, uplands and lowland swamps. They require 

five basic habitat components: escape cover, fall sources of mast, spring and summer feeding 

areas, movement corridors and winter denning habitat (Garshelis and Pelton 1981). 

Marten (Martes americana) are a valuable furbearer considered to be a provincially featured 

species for timber management in the boreal forest of Ontario according to the Environmental 

Assessment Board. Marten generally inhabit late-successional, mesic to moist conifer and 

conifer dominated mixedwood forest types, with a preference for mixed versus pure conifer 

stands. Overhead conifer canopy cover is an important component of marten habitat as it limits 

snow depth, moderates winter temperature regimes and provides summer resting cover. 

Cavities in live or dead standing trees or fallen logs are used as maternal denning sites. 

Complex physical structure at ground level in the form of coarse woody debris is also an 

important habitat element as it allows access to the subnivean space used for hunting during 

winter and serves as habitat for important small mammalian prey such as voles and mice. 

Although red-backed voles (Clethrionomys gapperi), meadow voles (Microtus pennsylvanicus) 

and snowshoe hare (Lepus americanus) are principle items in the diet, marten are opportunistic 

feeders that consume a wide variety of plant and animal items. Marten have low reproductive




rates, relatively slow development as compared to other mammals and occur at low density on 

the landscape (OMNR 1996). 

Canada lynx (Lynx canadensis) are managed as furbearers in Ontario, and are the most widely 

distributed cat species in Canada. Their range closely matches that of their main prey species, 

the snowshoe hare. Lynx inhabit boreal and sub-boreal forest types, preferring regenerating 

stands greater than 20 years of age with abundant ground litter, while generally avoiding 

younger and recently disturbed stands. Lynx population size fluctuates widely over 8-11 year 

periods, reflecting variations in snowshoe hare abundance, with a lag of 1-2 years (Poole 2003). 

Lynx are carnivorous, and while snowshoe hare make up the majority of the diet, red squirrels 

(Tamiasciurius hudsonicus), muskrat (Ondatra zibethicus), meadow voles, white-tailed deer 

fawns, upland game birds and carrion may all be eaten. Male and female lynx maintain fairly 

large territories of up to 50 km 2 and with the exception of the breeding season in late-winter, 

stay within their own territory. Lynx are capable of a high reproductive output during times of 

resource abundance and have been shown to disperse great distances in response to local 

perturbations. These factors make lynx populations fairly resilient to localized habitat 

disturbance, particularly given time and removal of the disturbance. 

The beaver (Castor canadensis) is an important keystone species of significant cultural value in 

Ontario. While it occurs in a variety of habitats, it prefers to live in slow-moving streams or lakes 

adjacent to young or regenerating forest stands of willow, alder and aspen. The dam building 

activities of beavers result in large scale alterations to the landscape, including the formation of 

ponds and meadows, long-term changes in vegetation communities, geologic and hydrological 

features, nutrient cycling, as well as changes in local vertebrate and invertebrate communities 

(Ives 1942, Naiman et al. 1988). Beavers cut large amounts of wood from riparian areas for use 

in the building of dams and lodges. The impoundments resulting from dam construction 

increase safety from predators and improve access to food resources. Beaver lodges serve as 

protection from predators, sites for parturition and as a means of moderating extreme 

temperatures during winter. While a variety of tree species may be selected as building 

materials, the bark, leaves and twigs of birch (Betula sp.), willow (Salix sp.) andaspen (Populus 

spp.) are preferred as food sources. Prior to the onset of winter, beavers stockpile large 

volumes of branches submerged or partially submerged in close proximity to their lodges. 

During the summer, beavers include aquatic and semi-aquatic plants as well as terrestrial herbs 

and forbs in their diet. Beavers are monogamous, mating during the winter, with young born in 

late May or early June. While relatively secure from predators when near or in water, wood 

harvesting on land or overland dispersal exposes beavers to predation. The most important 

predators of the beaver are wolves and coyotes, but red foxes, black bears, lynx and wolverines 

will all occasionally prey on beavers. 

Muskrat (Ondatra zibethicus) are a common and important furbearer in Ontario. Semi-aquatic, 

muskrats always live near slow-moving streams, ponds, lakes, and in particular, marshes. 

Preference is for standing water approximately 1.5 – 2.0 m deep. These conditions support 

growth of aquatic plants such as arrowhead (Sagittaria sp.), water lily (Nymphaea sp.), cattail




and various rush species (Typha sp.), the roots and basal portions of which are preferred as 

food. In addition to aquatic vegetation, muskrat will also include some meat in their diets in the 

form of mussels, crayfish, turtles, frogs and small fish. Muskrat den either in shoreline banks 

where they excavate underground chambers just above the waterline, or in mounds constructed 

of mud, cattails, bur-reed and bulrushes. These den sites are used year-round, and provide 

protection from predators and extreme temperatures during the winter. Muskrat produce up to 3 

litters of 4 – 8 young per year, with fewer litters produced as latitude increases (Simpson and 

Boutin 2006). Dependent on region, racoon and mink are the principle predators of muskrat, 

although foxes, eagles and hawks also contribute to mortality. 

Like the marten, fisher (Martes pennanti) are a provincially featured species for timber 

management in the boreal forest according to the Environmental Assessment Board. Also 

similar to the marten, fisher will inhabit mature conifer forest types with dense canopy cover. 

However, unlike marten, fisher will inhabit mature deciduous forests as well as regenerating 

second-growth and mid-stage mixed-wood forests (Brander and Brooks 1973). Fisher show 

general avoidance of recently cleared or open areas. Availability of food and canopy structure 

are the most important determinants of habitat selection (OMNR 1986). Fisher have a diet 

similar to that of marten, including snowshoe hare, red squirrels, voles and mice, but are also an 

important predator of porcupines (Erethizon dorsatum). Ruffed grouse (Bonasa umbellus) and 

blue jays (Cyanocitta cristata) may be taken incidentally, as will carrion if available. During 

summer, berries may contribute as much as 20% to the diet. Fisher use cavities in trees with a 

diameter at breast height greater than 50 cm as maternal den sites. Adult fisher have no 

significant predators other than humans, although hawks, eagles, foxes, lynx and bobcat may 

occasionally prey on juveniles. 

River otters (Lutra canadensis) are valuable furbearers in Ontario. Otters require clean, 

moderately deep ponds, lakes or streams removed from human disturbance, preferring 

waterways with steep banks. Terrestrial vegetation adjacent to the inhabited water body factors 

little into habitat selection, although coarse woody debris along the lake shore may be used as 

resting cover. Otters generally benefit from the presence of beavers by taking advantage of 

felled trees, abandoned lodges and logjams as cover and denning sites. Otters are a semiaquatic 

carnivore. They feed primarily on fish, including carp, sucker species, cyprinid species, 

stickleback and darter species, but will also include crayfish, clams, amphibians and small 

mammals in their diet. Trapping and hunting are principle causes of otter mortality. 

The red fox (Vulpes vulpes) is a common furbearer in Ontario. Foxes are generalists in terms of 

the habitats they select. Preference is generally for transition or edge areas between open and 

wooded habitat types with avoidance of large, unbroken tracts of mature forests. They are 

adaptable to disturbances in their habitat and in certain instances may even benefit from 

anthropogenic modifications to the landscape. Home range size is generally related to habitat 

heterogeneity, with foxes occupying smaller home ranges in more complex habitats. Foxes are 

solitary during most of the year, maintaining territories varying widely in size from less than 1 to 

greater than 50 km 2 (Lucherini and Lovari 1996). Breeding occurs from early January through




March, during which time monogamous pairs form and defend a territory. Following parturition, 

both adults contribute to raising young. Families disband starting late in September, with 

juvenile dispersing up to 30 km from the territories of their parents. Although largely carnivorous, 

foxes are functionally omnivorous, feeding on small mammals including snowshoe hares, 

squirrels, voles and mice, but consuming mast when available. Foxes will also prey on groundnesting 

birds such as certain waterfowl and upland game bird species as well as crayfish, 

reptiles, amphibians and invertebrates. As adults, red foxes have few predators, although lynx, 

bobcat, coyotes, some hawks and owls may occasionally prey on juveniles. 

Species at Risk – Woodland Caribou 

All caribou subspecies are members of the Genus Rangifer and the species tarandus and are 

probably capable of interbreeding. However, Banfield recognized 9 subspecies based on skull 

morphology, with 6 occurring in North America (Banfield 1961). Among those subspecies there 

are also considered to be 2 ecotypes based on the distribution patterns of cows in order to 

reduce predation risk. The first ecotype can be widely spaced throughout the landscape in order 

to increase search time by predators. This spaced-out strategy belongs to the sedentary 

ecotype, also known as the woodland caribou. The second ecotype spaces away from 

predators to specific calving grounds in the spring. This spacing away strategy belongs to the 

migratory ecotype, also known as the forest-tundra woodland caribou (Schaefer et al 2000). The 

subspecies referenced in this report is the sedentary or forest-dwelling woodland caribou 

(Rangifer tarandus caribou; hereafter, caribou). 

Caribou occur at low densities across most of their range in Canada (Schaefer 2003) and have 

been listed as a threatened species throughout mainland Canada (COSEWIC 2000) including 

Ontario. Management to maintain caribou habitat has long revolved around the paradigm that 

caribou need mature and old-growth conifer stands with low canopy closure and an abundance 

of lichens, especially in winter (Rettie and Messier 2000, Courtois et al. 2007, Schaefer and 

Mahoney 2007). As forestry operations expand across the boreal forest, caribou habitat of this 

description continues to be altered in favour of younger, managed forest (Schaefer 2003, Vors 

et al. 2007, Wittmer et al. 2007). An indirect consequence of habitat alteration is functional 

habitat loss, which occurs when other ungulate species are attracted to the younger forests 

(Courtois et al. 2004, Wittmer et al. 2007), allowing an increase in predator populations (Rettie 

and Messier 1998, Kunkel and Pletcher 2001, McLoughlin et al. 2005, Briand et al. 2009). 

The management of caribou habitat has become a significant consideration in the preparation of 

Forest Management Plans (FMPs) and mine permitting throughout the boreal forest, because of 

progressive loss of caribou range and functional habitat throughout Canada over the last 

century (McLoughlin et al.2003, Courtois et al. 2004, Vors et al. 2007). 

The onus of the protection and management of caribou lies with the OMNR, primarily through 

the forest management planning process and takes the form of habitat management and the 

reduction of stressors. Identification and conservation of caribou habitat in the boreal forest of 

Ontario within the context of forest management planning has evolved from the Forest 

Management Guidelines for the Conservation of Woodland Caribou: A Landscape Approach




(Racey et al. 1999) to the Forest Management Guide for Boreal Landscapes (OMNR in prep), 

the Ontario Woodland Caribou Conservation Plan (OMNR 2009a), the Cervid Ecological 

Framework (OMNR 2009b) and the Forest Management Guide for Conserving Biodiversity at 

the Stand and Site Scale (OMNR 2010). 

The Ontario Woodland Caribou Conservation Plan (CCP), which provides policy direction for 

caribou management, has proposed 8 “Caribou Population Ranges” in Ontario that form the 

management units by which caribou habitat will be managed. The Springpole study area is 

located in the northern portion of the Churchill Caribou Range (Figure 2.14). Some of the 

pertinent principles guiding the CCP include (OMNR 2009b): 

• Ecosystem based management that considers all the natural factors that affect and 

sustain caribou 

• A focus on the long-term sustainability of caribou ranges including the consideration of 

cumulative impacts 

• Consideration of caribou population health and habitat condition in resource 

development decisions 

• Consideration of social, economic and environmental concerns in the context of longterm 

caribou survival. 

Caribou recovery in Ontario is based on the range management approach, whereby a caribou 

range is the basis for identifying the amount and arrangement of habitat and assessing 

cumulative impacts. The criteria of range delineation include: survey data (movements, 

distributions and evidence of shared geography), habitat functions and behavioural responses, 

and predominant risk factors. The range management approach sets the ecological context for 

decision making which will consider the factors that influence caribou well-being, including direct 

and indirect human impacts (OMNR 2009a). 

The term “cervid” is used to describe any member of the deer family including caribou, moose, 

white-tailed deer and elk. The Cervid Ecological Framework (CEF) provides policy advice for 

broad, landscape-level management of cervids in relation to each other in the broader context of 

the ecosystems they share (OMNR 2009b).




Species at Risk - Wolverine 

The wolverine is the largest member of the Weasel family (Mustelidae), and has been described 

as a “scavenging predator” that depends on carrion, as well as berries, fish, small mammals, 

birds, and any other prey it can catch (Hash 1987). 

Wolverines are known to use a variety of northern habitat types including tundra, arctic coastal 

areas, rocky outcrops in mountainous landscapes and boreal forest. In Ontario, wolverines 

avoid deciduous forest types, instead favouring mature conifer stands. Areas with road networks 

and/or those managed for timber harvest are also avoided (Bowman et al. 2010). Generally, 

wolverines seem sensitive to human disturbance to the extent that wolverine habitat appears 

limited by the ‘human footprint’ on the landscape. Wolverine tracks were seen during the aerial 

survey in 2011 east of Springpole Lake (Figure 2.13). 

Wolverines occur at low densities on the landscape. They have exceptionally large home 

ranges and display relatively low reproductive capacity. These factors contribute to the animal’s 

inability to cope with human-caused mortality and to recover in areas where they have been 

extirpated (Hash 1987). Wolverine harvest is considered to be additive to natural mortality and it 

was suggested by Krebs et. Al. (2000) that immigration from un-harvested populations was 

required to support hunted populations. Wolverine are listed as Threatened provincially and 

special concern federally. 

Significant Wildlife Habitat 

In May 1996, the Provincial Policy Statement (PPS) in Ontario was issued under the Planning 

Act. Section 2.3 of the PPS states that “natural heritage features and areas will be protected 

from incompatible development”. Site alteration and/or development on or adjacent to these 

areas will be permitted, “if it can be demonstrated that there will be no negative impact on the 

natural features or ecological functions for which the area is identified”. The OMNR prepared a 

document entitled the Significant Wildlife Habitat Technical Guide to assist in land use planning 

as well as applications that must fulfill other approval processes such as Class Environmental 

Assessments. 

The Significant Wildlife Habitat Technical Guide contains four categories of significant wildlife 

habitat. Wildlife habitat is considered significant where it is “...ecologically important in terms of 

features, functions, representation or amount, and contributing to the quality and diversity of an 

identifiable geographic area or Natural Heritage System. Criteria for determining significance 

may be recommended by the Province, but municipal approaches that achieve the same 

objective may also be used” (OMNR 2000). 

The four categories include; habitats of seasonal concentrations of animals, rare vegetation 

communities or specialized habitats for wildlife, habitats of species of conservation concern, and 

animal movement corridors. Each of these four categories will be discussed below with regard 

to their importance and their presence in the Springpole study area.




Habitats of Seasonal Concentrations of Animals 

Wildlife can concentrate in relatively small areas during certain times of the year. Areas of 

seasonal concentrations are important to wildlife because they provide cover, protection, access 

to food sources, nesting and breeding sites. If these sites are limited they can directly influence 

populations and result in a loss of associated wildlife. Although the MNR does have some 

information on the locations of habitats of seasonal concentrations of animal within their NRVIS 

database, they have stated that “The MNR has not attempted to identify or survey any of these 

values within the wildlife study area...no recent surveys have been conducted in this area so the 

data may be out of date or inaccurate.” (pers. comm. with Leslie Barns – Red Lake OMNR). 

Therefore, it is worth noting that, although some of these significant habitats were not 

discovered through field investigations conducted by DST, this does not mean that they don’t 

exist within the study area. 

Winter deer yard - No winter deer yards are known to occur within the RSA or the LSA. The 

study area is located north of the core range of white-tailed deer, however, very small numbers 

of deer have been seen in the area on occasion. There is a total of 5 ha of potential winter deer 

yard habitat (dense cedar swamps; ecosite 37) located approximately 25 km southwest of 

Springpole Lake. The study area is located within Cervid Ecological Zone A as specified in the 

CEF (OMNR 2009b), and as such, has a management focus of low density deer populations. 

Moose late winter habitat – The OMNR has not identified any known moose late winter habitat 

within the RSA or the LSA, however, the OLT modelling has indicated that late winter moose 

habitat is abundant throughout the study area as well as the surrounding area (Figure 2.15). 

The CEF (OMNR 2009b) indicates that the management focus for this zone is for low density 

moose populations with no emphasis on moose habitat management except where appropriate 

as per species specific policy direction. 

Caribou wintering habitat – This is covered in Section 3.4 

Colonial bird nesting sites – Colonial nesting birds that have the possibility of occurring within 

the study area (according to Significant Wildlife Habitat technical guide - OMNR 2000) include: 

Turkey vulture (Cathartes aura), Short-eared owl (Asio flammeus), Purple martin (Progne 

subis), Double-crested cormorant (Phalacrocorax auritus), Great blue heron (Ardea Herodias), 

Ring-billed gull (Larus delawarensis), Herring gull (Larus argentatus), Common tern (Sterna 

hirundo), Black tern (Chlidonias niger), Bank swallow (Riparia riparia), Cliff swallow (Hirundo 

pyrrhonota), Barn swallow (Hirundo rustica), Red-winged blackbird (Agelaius phoeniceus), and 

Common grackle (Quiscalus quiscula). The only colonial nesting site identified by the OMNR 

within the RSA or the LSA is a heron rookery, however, two Bonaparte’s gull nesting colonies 

were discovered by DST near the north end of Springpole Lake in 2011 and in 2012 during 

breeding bird surveys (Figure 2.16). No other nesting colonies have been located within the 

study area, however, this does not mean that other nesting colonies do not exist within the study 

area. 

Waterfowl stopover and staging areas - The OMNR has not identified any known waterfowl 

stopover and staging areas within the RSA or the LSA. Staging areas are generally found in




large wetlands adjacent to large bodies of water (OMNR 2000). There are very few large 

wetlands in the study area. A waterfowl survey was conducted on Springpole Lake as well as a 

number of smaller ponds within the study area (Figure 2.16). Although some waterfowl species 

were observed during the survey, no significant stopover or staging areas were identified.




Waterfowl nesting sites - The OMNR has not identified any known waterfowl nesting sites within 

the RSA or the LSA. Significant waterfowl nesting sites are usually associated with large, 

undisturbed upland areas that contain abundant ponds and wetlands (OMNR 2000). As 

previously mentioned, there are very few large wetlands located within the study area. Nesting 

locations were discovered for a ring-necked duck (Aythya collarisand), and a common loon 

(Gavia immer) (Figure 2.16) 

Shorebird migratory stopover areas - The OMNR has not identified any known shorebird 

migratory stopover areas within the RSA or the LSA. During the migratory bird and waterfowl 

surveys, no significant shorebird migratory stopover areas were identified within the RSA or the 

LSA. 

Landbird Migratory stopover areas - The OMNR has not identified any known landbird migratory 

stopover areas within the RSA or the LSA. During the migratory bird and waterfowl surveys, no 

significant landbird migratory stopover areas were identified within the RSA or the LSA. 

Raptor winter feeding and roosting areas – The OMNR has not identified any known raptor 

winter feeding and roosting areas within the RSA or the LSA. Areas important for the survival of 

birds of prey include open fields that support large and productive small mammal populations. 

Roosting sites for raptors tend to be associated with mature mixed or coniferous forests 

adjacent to open fields (OMNR 2000). The study area lacks any appreciable open fields, 

therefore, no important raptor winter feeding and roosting areas were identified. 

Turkey vulture summer roosting areas – Turkey vultures tend to roost on cliff ledges and dead 

trees in undisturbed areas, and often near water. The OMNR has not identified any known 

turkey vulture summer roosting areas within the RSA or the LSA and none were identified 

during field investigations. 

Reptile hibernacula – Animal burrows and rock crevices enable reptiles to hibernate below the 

frost line. Some species of snakes and turtles can overwinter in sizable concentrations within 

these areas. Very few hibernacula are known and they are normally very difficult to locate 

(OMNR 2000). The OMNR has not identified any known reptile hibernacula within the RSA or 

the LSA and none were identified during field investigations. 

Bat hibernacula – Winter hibernacula, which are usually located in caves or abandoned mines, 

must have interior air temperatures slightly above freezing, relative humidity levels above 90 % 

and provide sufficient space for roosting (OMNR 2000). There are no known caves or 

abandoned mines within the study area. The OMNR has not identified any known bat 

hibernacula within the RSA or the LSA and none were identified during field investigations. 

Old-growth or mature forest stands – Definitions of old-growth vary depending on the tree 

species involved, however, stands of 120 or 140 years of age of any species tend to be 

considered old-growth. Because the study area is located at the northern extent of the managed 

forest in Ontario, there has been little to no logging activity, resulting in the presence of 

significant old growth stands (Figure 2.17).




Specialized raptor nesting habitat – Several raptors require somewhat specialized nesting 

habitat for their long-term survival. A number of raptor nests have been identified within the RSA 

and the LSA (Figure 2.18). Some of these nesting sites have been identified through OMNRs 

NRVIS database, and some have been observed by DST while conducting field investigations. 

Moose calving areas – Calving locations are usually located on elevated areas on islands or 

peninsulas, as well as upland areas close to water (OMNR 2000). No moose calving sites were 

identified through OMNR NRVIS data within the study area. 

Moose aquatic feeding areas (MAFAs) – Preferred aquatic feeding sites have abundant 

pondweeds, water milfoil, and yellow water lily. They are also located adjacent to stands of 

lowland conifers (OMNR 2000). The OMNR has identified two MAFAs within the RSA (Figure 

2.19). No additional MAFAs have been identified within the RSA or LSA. 

Mineral licks – Moose seek out sodium found in upwellings of groundwater in the spring. These 

areas may be used by large concentrations of moose over many years. These sites are rare 

and occur on granitic bedrock overlain by calcarious glacial till (OMNR 2000). The OMNR has 

not identified any known mineral licks within the RSA or the LSA, however, one was located by 

DST during field investigations (Figure 2.19). 

Mink, otter, marten and fisher denning sites – These members of the weasel family have large 

home ranges and are rarely found in high densities, therefore, they tend to have specific habitat 

components critical to their survival (OMNR 2000). Feeding and denning sites for these 

mammals are very hard to find, and their survival is best assured through large-scale forest 

management planning (OMNR 2000). The OMNR has not identified any known denning sites 

within the RSA or the LSA and none were identified during field investigations. 

Identification of habitats of species of conservation concern – Species that can be considered 

species of conservation concern include (OMNR 2000): 

 

 

 

 

 

 

 

Species identified as nationally endangered or threatened by the Committee on the 

Status of Endangered Wildlife in Canada, which are not protected in regulation under 

Ontario’s Endangered Species Act 

Species identified as provincially vulnerable based on lists of Vulnerable, Threatened, 

Endangered, Extirpated, or Extinct Species of Ontario that are updated periodically by 

the OMNR (Appendix P) 

Species that are listed as rare or historical in Ontario based on records kept by the 

Natural Heritage Information Centre in Peterborough (S1 is extremely rare, S2 is very 

rare, S3 is rare to uncommon) 

Species whose populations are known to be experiencing substantial declines in Ontario 

Species that have a high percentage of their global population in Ontario and are rare or 

uncommon in the planning area 

Species that are rare within the planning area, even though they may not be provincially 

rare 

Species that are subjects of recovery programs (e.g., the Black Duck Joint Venture of 

the North American Waterfowl Management Plan)




 

Species considered important to the municipality, based on recommendations from the 

Conservation Advisory Committee Habitat for these species is exclusive of those 

habitats for species covered under the ESA




According to the Significant Wildlife Habitat Technical Guide, species of conservation concern 

do not include species that have been designated as threatened or endangered by the OMNR. 

This is because species designated as threatened or endangered by the OMNR are protected 

by the Ontario Endangered Species Act (ESA) and are managed through ESA related 

regulation. Many species of conservation concern are uncommon or rare species that normally 

do not exhibit high population densities or have specialized habitat requirements that may be 

poorly understood. A list of the species of conservation concern that have the possibility of 

occurring within the study area are listed in Table 3.6.1. The Natural Heritage Information 

Centre (NHIC) uses a provincial ranking system to set protection priorities for rare species and 

natural communities. A species that is ranked as an S1, S2 or S3 is considered provincially rare. 

 

 

 

S1 Extremely rare in Ontario; usually 5 or fewer occurrences in the province or very few 

remaining individuals; often especially vulnerable to extirpation. 

S2 Very rare in Ontario; usually between 5 and 20 occurrences in the province or with 

many individuals in fewer occurrences; often susceptible to extirpation. 

S3 Rare to uncommon in Ontario; usually between 20 and 100 occurrences in the 

province; may have fewer occurrences, but with a large number of individuals in some 

populations; may be susceptible to large-scale disturbances. 

Of the species listed in Table 3.6.1, the habitat of woodland caribou was found in the study area 

(covered in Section 3.4) as well as bald eagle. 

Identifying animal movement corridors – Animal movement corridors can encompass a wide 

variety of landscape features including riparian zones, valleys, ridges and abandoned roads. 

The PPS states that “natural connections between natural features should be maintained and 

improved where possible”. The identification of animal movement corridors can be very difficult 

as animals are rarely seen utilizing these corridors. Some suggestions as to features that may 

be incorporated into a corridor include: large natural areas, large and old forest stands, and the 

largest and most diverse wetlands. The OMNR has not identified any known animal movement 

corridors within the RSA or the LSA and none were identified during field investigations. 

However, road cameras have been deployed throughout the LSA in the hopes of assisting in the 

identification of movement corridors, but at the time this report was written, no movement 

corridors have been determined. 

Aquatics 

The headwaters for several major rivers are located within this ecoregion, with some flowing 

westward into Manitoba, but most flow northeastward into Hudson and James Bays. The Trout 

Lake FMP identifies Springpole Lake, Birch Lake and Seagraves Lake as coldwater lakes, and 

Bertha Lake, McNaughton Lake and Dead Dog Lake as cool water lakes according to their 

thermal characteristics and associated fish communities (Figure 2.20). For the purposes of this 

study it will be assumed that all tributaries have the same designation as their respective lake 

designation. If the designation of a waterbody is unknown, it will be assumed to be coldwater 

unless proven otherwise. Fish species typically associated with coldwater lakes include lake




trout (Salvelinus namaycush), northern pike (Esox lucius), whitefish (Coregonus clupeaformis), 

white sucker (Catostomus commersoni) and lake herring (Coregonus artedii). Coolwater fish 

species include walleye (Sander vitreum), northern pike (E. lucius), and yellow perch (Perca 

flavescens). Fish species known to inhabit Springpole Lake include: lake trout (S. namaycush), 

walleye (S. vitreum), lake whitefish (C. clupeaformis), pike (E. lucius), common white sucker (C. 

commersoni), yellow perch (P. flavescens), rock bass (Ambloplites rupestris), fine-scale dace 

(Chrosomus neogaeus), brook stickleback (Culaea inconstans) and nine-spine stickleback 

(Pungitius pungitius). 

Cyprinid species whose known ranges overlap the study area include northern redbelly dace (C. 

eos), lake chub (Couesius plumbeus), golden shiner (Notemigonus crysoleucas), emerald 

shiner (Notropis atherinoides), blacknose shiner (N. heterolepis), spottail shiner (N. 

hundsonicus), mimic shiner (N. volucellus), bluntnose minnow (Pimephales notatus), fathead 

minnow (P. promelas), blacknose dace (Rhinicthys atratulus), longnose dace (R. cataractae) 

and pearl dace (Semotilus margarita) (Scott and Crossman 1998). The known ranges of Iowa, 

johnny and river darters (Etheostomus exile and E. nigrum and Percina shumardi respectively) 

also overlap the study area. Longnose sucker (Catostomus catostomus), shorthead redhorse 

sucker (Moxostoma macrolepidotum) and log perch (Percina caprodes) may also occur in the 

study area. 

Preliminary investigations of the water courses in the study area indicated that the waterbodies 

are typical of boreal shield creeks, ponds and lakes with flat to moderate channel gradients and 

sections of steeper, faster moving water usually associated with bedrock outcrops. Many of the 

creeks in the area appear to be ephemeral and for the most part, have discontinuous flows 

during the dryer times of the year. The aquatic habitats found in the study area are common and 

widespread throughout the area, capable of supporting a wide range of aquatic species 

throughout all life stages. 

The Birch River has its outflow at the eastern end of Springpole Lake, draining Springpole into 

Fawcett Lake. The Birch River is known to provide some of the most important walleye 

spawning habitat in the study area and may serve as year-round habitat for walleye. Lake trout, 

northern pike and whitefish all likely show seasonal use of the river, as either feeding (lake trout, 

northern pike, whitefish) or spawning (whitefish) habitat. The drainage from Cromarty Lake into 

the southwest corner of Springpole Lake also represents important walleye spawning habitat in 

the study area. While the area with strong currents is small, the drainage is likely used 

seasonally by lake trout, northern pike and whitefish as either feeding or spawning habitat. Dead 

Dog Creek, occurring in the southeast corner of the study area, may serve as spawning and 

nursery habitat for northern pike. The smaller creeks in the study area likely support relatively 

depauperate fish communities comprised of a limited number of cyprinid, stickleback and darter 

species. 

A Lake Sturgeon (Acipenser fulvescens rafinesque) survey on Springpole Lake was conducted 

in 2012. To date, a total of 44 large mesh gill nets have been fished at depths ranging from 2 m 

to 33 m in an effort to determine the presence or absence of sturgeon. Large mesh gill nets




have been utilized because they target adult sturgeon and because the catch of other species is 

very low. Although no sturgeon have been captured to date, fishing efforts will continue during 

the spring and fall of 2013. Should the presence of Lake Sturgeon be confirmed through gill net 

captures, an acoustic tagging program will be initiated. The goal of acoustic tagging work will be 

to characterize fish movement to and from Springpole Lake, and aid in the identification of 

potential critical Lake Sturgeon habitat (e.g. spawning areas). A network of 10 acoustic 

receivers has been installed in Springpole Lake. In the event that adult sturgeon are captured, 

acoustic tags will be implanted and monitored for a period of up to three years. With the 

exception of the Birch River crossing, none of the proposed water crossings associated with 

either road corridor appears capable of harbouring a population of sturgeon. In addition, none of 

these areas appears suitable for sturgeon spawning. The suitability of the Birch River as 

sturgeon spawning habitat will be assessed in the Spring of 2013.




3.0 Environmental Effects Analysis 

Terrestrial Environment 

Environmental Effects 

Planning efforts have focused on minimizing the area potentially impacted through road 

construction. Table 3.1.1 presents ecosite and FU definitions, while Table 3.1.2 and Table 3.1.3 

present the total area and percent area of ecosites and forest units respectively for the entire 

Trout Lake Forest. In total, the area affected through the construction of road option A and B 

would be 39.21 ha, and 64.56 ha respectively. The total area by ecosite and forest unit affected 

by each road option is presented in Table 3.1.4 and 3.1.5 respectively. 

The projected area of newly disturbed forest habitat associated with each corridor option would 

constitute a very small portion of the Trout Lake Forest, estimated at 0.004 % for option B and 

0.013 % for option A. Even the proposed timber harvest area only constitutes 0.04% of the total 

area of the Trout Lake Forest. Option A would alter a larger portion of forested habitat (64.56 

ha) compared to Option B (39.21 ha), however, the overall areas potentially affected for both 

options and the harvest area is fairly small on a landscape scale. The proportions of ecosites 

and forest units that will potentially be affected are fairly similar for both options and neither 

option would affect the less common ecosites found in the Trout Lake Forest such as B129. 

Vegetation clearing for road corridor construction may increase the potential for changes in 

community structure of vegetation at the forest edge. The most common effect would be 

increases in light penetration and drying, with the majority occurring on southerly oriented forest 

edges. These effects are not expected to extend more than a few meters into the surrounding 

forest. Incidence of blow-down are not expected to increase measurably as winds across 

narrow roadways seldom gain the required strength to knock down trees. The effects on road 

edges are therefore expected to be very minimal with only minor changes to the structure of 

vegetation communities for both linear corridor options. 

Mitigation 

Winter time vegetation removal for the corridor will allow GCU to begin constructing during a 

period that will minimize impacts to forest soils and understory vegetation. The potential impacts 

to native vegetation communities will be minimized where possible by restricting clearing to 

minimal acceptable standards and following the Stand and Site guide guidelines. Constructing a 

road corridor of minimal width will have the added benefits of lowering the costs of construction 

and facilitating rehabilitation if the project does not advance beyond the current exploration 

stage. Corridor layout and construction will follow the principles outlined in Environmental 

Guidelines for Access Roads and Water Crossings (MNR, 1995), Forest Management Guide for 

Conserving Biodiversity at the Stand and Site Scales (MNR, 2010), and the Crown Land Bridge 

Management Guidelines (MNR, 2008). 

Areas deemed to be “sensitive” will be avoided to the extent practicable. Minimum set-backs of 

100 m will be placed around waterbodies and other significant natural features where possible 

(i.e. wetlands, riparian areas). As per Table 5.1b of the Stand and Site guide, roads built within




15 m of a water feature and not associated with a water crossing will; use techniques and 

practices to reduce the possibility of roadbed erosion; avoid grubbing; and design ditches to 

minimize the possibility of sediment entering the water feature. This will allow for the protection 

of riparian habitats which are integral components of ecological sustainability with regard to 

wildlife and water quality. 

GCU will be committed to regenerating impacted sites to their original vegetative community, 

once the selected corridor alternative is no longer utilized. 

Significance 

The overall magnitude of the effect of vegetation clearing is considered to be low with regard to 

the terrestrial environment, provided that the proposed mitigation measures are followed. In 

terms of the terrestrial values (i.e. ecosites and forest units) that could potentially be affected, 

they are all common within the LSA, the RSA and the Trout Lake Forest. The values in question 

that could be considered the highest priority, would be the wetland ecosites (B126, B127, 

B128). The disturbance to these ecosites would be minimal as road construction planning tends 

to avoid low lying, wet areas wherever possible. The geographic extent of the environmental 

effects would be quite localized and therefore considered low. Determining the duration of the 

potential environmental effects is more difficult as the anticipated duration of use of the selected 

road corridor is difficult to predict. Regardless of the duration, use would be finite, with 

rehabilitation occurring after closure. 

Based on the information provided in this report and taking into account the proposed mitigation 

measures, the proposed project is not likely to result in any significant adverse environmental 

effects on the terrestrial environment. 

Comparison of effects 

A comparison of both road options indicates that the potential effects of each option are fairly 

similar in terms of the magnitude, affected values, duration and reversibility. Option A covers a 

larger geographic extent, but the difference in overall area affected is negligible.




Table 3.1.1 Provincial Ecosite and Forest Unit definitions within the Trout Lake Forest that have 

the potential to be affected by the Project 

Ecosite/ 

Forest Unit 

Description 

B049 

Dry to fresh, coarse:Jack Pine - Black Spruce Dominated 

B052 

Dry to fresh, coarse: Spruce-Fir Conifer 

B055 

Dry to fresh, coarse: Aspen-Birch Hardwood 

B065 

Moist, Coarse:Black Spruce-Pine Conifer 

B082 

Fresh, Clayey:Black Spruce-Jack Pine Dominated 

B088 

Fresh, Clayey:Aspen-Birch Hardwood 

B098 Fresh, Silty to Fine Loamy:Black Spruce-Jack Pine Dominated 

B101 

Fresh, Silty to Fine Loamy:Spruce-Fir Conifer 

B104 

Fresh, Silty to Fine Loamy:Aspen-Birch Hardwood 

B114 

Moist, Fine:Black Spruce-Pine Conifer 

B126 

Low Treed Bog 

B127 

Organic Poor Conifer Swamp 

B128 

Organic Intermediate Conifer Swamp 

UNCL 

Unclassified 

BWD 

white birch dominated stands 

CMX 

mixed conifer stands with minimal hardwood 

HMX 

mixed hardwood dominated stands 

OCL 

larch and cedar dominated lowland stands 

PJM 

jack pine dominated mixedwood stands 

PJP 

jack pine dominated stands with minimal poplar component 

POA 

poplar dominated stands 

PRW 

red pine dominated mixedwood stands 

SBL 

lowland black spruce stands 

SBM 

black spruce dominated mixedwood stands 

SBP 

upland black (or white) spruce stands with minimal hardwood 

SHA 

conifer dominated shallow sites




Table 3.1.2 Number of polygons (count), total area (ha) and percentage of total area of ecosites 

found in the Trout Lake Forest 

Ecosite Count Area (ha) 

% Total 

Area 

B011 1 8.12 0.00 

B012 2370 30544.92 3.79 

B034 1724 28217.26 3.50 

B035 463 5138.60 0.64 

B040 96 646.00 0.08 

B048 5 31.28 0.00 

B049 26976 310614.08 38.50 

B051 24 184.45 0.02 

B052 10984 103597.38 12.84 

B055 3457 36964.90 4.58 

B065 6154 44530.61 5.52 

B070 135 928.96 0.12 

B082 3366 33260.38 4.12 

B088 851 9094.28 1.13 

B089 9 94.18 0.01 

B097 3 18.00 0.00 

B098 889 9381.49 1.16 

B101 384 3955.98 0.49 

B104 389 4194.77 0.52 

B114 1481 11996.19 1.49 

B116 659 4319.42 0.54 

B119 183 1329.85 0.16 

B126 597 4109.84 0.51 

B127 9838 65238.73 8.09 

B128 13001 98293.52 12.18 

B129 18 82.85 0.01 

B130 10 54.83 0.01




Table 3.1.3 Total area (ha) and percentage of total area of forest units found in the Trout Lake 

Forest 

Forest 

Unit 

Area (ha) 

Precent of 

Total Area 

UNCL 224425.74 21.76 

BWD 2836.67 0.28 

CMX 63041.42 6.11 

HMX 39283.69 3.81 

OCL 3967.10 0.38 

PJM 70201.87 6.81 

PJP 112798.34 10.94 

POA 16480.45 1.60 

PRW 11.32 0.00 

SBL 163812.70 15.88 

SBM 83035.21 8.05 

SBP 220809.21 21.41 

SHA 30553.05 2.96 

Table 3.1.4 Total area of ecosites potentially affected (ha) and percent of total ecosite area 

potentially affected by each road option in the Springpole study area 

Option A 

Option B 

Ecosite 

Area Lost 

(ha) 

% Total 

Ecosite Area 

Area Lost 

(ha) 

% Total 

Ecosite Area 

B049 27.94 0.009 11.02 0.004 

B052 10.36 0.010 7.28 0.007 

B055 1.08 0.003 4.71 0.013 

B065 1.26 0.003 0.39 0.001 

B082 13.39 0.043 6.38 0.021 

B088 0.00 0.000 0.79 0.009 

B098 0.00 0.000 0.24 0.003 

B101 0.11 0.003 0.30 0.008 

B104 0.83 0.020 0.31 0.007 

B114 0.34 0.003 0.89 0.007 

B126 0.56 0.014 0.00 0.000 

B127 4.76 0.007 1.49 0.002 

B128 2.73 0.003 3.80 0.004




Table 3.1.5 Potential area of Forest units (ha) and percent of total forest unit areas potentially 

affected by each road option in the Springpole study area 

Option A 

Option B 

Forest 

Unit 

Area Lost 

(ha) 

% Total 

Area 

Area Lost 

(ha) 

% Total 

Area 

UNCL 1.40 0.001 2.25 0.001 

BWD 0.23 0.008 1.04 0.037 

CMX 5.39 0.009 11.53 0.018 

HMX 3.71 0.009 2.26 0.006 

OCL 0.00 0.000 0.00 0.000 

PJM 0.00 0.000 12.06 0.017 

PJP 0.00 0.000 4.15 0.004 

POA 2.11 0.013 0.13 0.001 

PRW 0.00 0.000 0.00 0.000 

SBL 5.30 0.003 25.06 0.015 

SBM 3.44 0.004 12.16 0.015 

SBP 17.45 0.008 65.49 0.030 

SHA 0.00 0.000 0.00 0.000 

Migratory Birds 


There are a number of potential ways that the proposed Project could affect birds (and other 

wildlife) including, but not limited to: 

• Mortality as a result of construction 

• Mortality as a result of vehicle collisions 

• Modification of behaviour (e.g. movement) 

• Habitat fragmentation and loss 

• Displacement due to invasive species 

• Increased predation 

The principle potential adverse effects of the Project on migratory birds would be those 

associated with direct habitat loss as a consequence of vegetation removal. The disturbance of 

nesting birds during the nesting season (April 1 st to August15 th ) is also a concern. Table 3.2.1 

presents the amount song bird breeding habitat that would be affected by each road corridor 

option. 

A total of 76 species were detected within the LSA, of which 2 are considered species at risk, 

provincially rare, or of special concern (Bald Eagle and Olive-sided fly catcher). The Olive-sided 

fly catcher is designated as threatened federally. A monitoring program for Whip-poor-will was




developed in conjunction with the OMNR SAR biologist. Monitoring through the use of 

automated song recorders was conducted around Springpole Lake. Monitoring in the proposed 

road corridor locations was not possible due to the difficulty of accessing the area. The project 

site is located north of the currently understood range of whip-poor-will, and none were 

recorded. 

Table 3.2.1 Amount (ha) of song bird breeding habitat that would be affected by each road 

corridor option 

Species 

Road 

Option A 

Road 

Option B 

Alder Fly Catcher 0.49 14.68 

Bay Breasted Warbler 0.00 0.00 

Blackburnian Warbler 0.00 0.00 

Brown Creeper 5.39 0.00 

Chestnut Sided Warbler 0.00 0.99 

Common Yellowthroat 0.00 1.73 

Least Flycatcher 0.00 0.00 

Ovenbird 31.70 28.70 

Red Brested Nuthatch 31.70 19.79 

Red Eyed Vireo 21.58 28.30 

Winter Wren 31.73 38.31 

Mitigation 

The following measures will be implemented in order to reduce the impacts of Project 

construction: 

• Construction of the linear corridor will occur outside the nesting season (April 1 st to 

August15 th ) for migratory birds 

• Minimizing the overall width of the corridor 

• Linear corridor will be decommissioned and re-vegetated to the extent possible 

• Maintaining, where practicable, a minimum 30 m buffer on all lakes, rivers, wetlands and 

unique or sensitive habitats 

• Following best management practices from the Stand and Site guide for song birds and 

other small birds 

Significance 

The overall magnitude of the potential effects is considered to be minimal as the total area that 

would be disturbed is quite small, particularly when compared to the area disturbed by forestry 

road building or harvesting each year. The potential negative effects that may occur to migratory 

birds will be very localized in geographical extent and will not impact any threatened or 

endangered avian species. Although the duration of the potential effects may be long-term (~20 

years), they are finite and reversible.




Overall, the potential impacts from habitat loss, fragmentation and alteration can be considered 

to be negative; however, the magnitude of these impacts can be considered low because of the 

relatively small areas being impacted and because no threatened or endangered avian species 

will be directly affected. 



similar in terms of the magnitude, affected values, duration and reversibility. Option A covers a 

larger geographic extent, but the difference in overall total habitat affected is negligible. 

Moose 


The potential adverse effects of Project construction on moose are those associated with habitat 

loss, general disturbance, and hunting mortality as a result of increased access. OLT modelling 

showed that predicted moose densities in the wildlife RSA are considered low (






similar in terms of the magnitude, duration and reversibility. Option A covers a larger geographic 

extent, but the difference in overall total habitat affected is negligible. The difference between 

the two options is in the values that could potentially be affected, with Option B located within a 

potential wildlife corridor. Also, Option A allows for a better ability to gate the road and restrict 

access due to the extent of leased claims associated with this option, thereby reducing the 

potential for mortality as a result of hunting.




Large Mammals and Furbearers 


The principle potential adverse effects of the linear corridor on large mammals and furbearers 

would be those associated with direct habitat loss, fragmentation and disturbance as well as the 

factors listed in Section 3.1. The environmental effects of habitat fragmentation are more difficult 

to ascertain than those of habitat loss. 

The negative effects of habitat fragmentation include increased isolation of forest patches and 

increased edge-to-interior ratios. Overall the environmental effects would benefit some species 

and be detrimental to others. Species that rely on early successional vegetation communities 

(e.g. black bear), as well as those associated with edges, could benefit from the Project. 

However, species that rely on late successional and/or interior forest habitats (e.g. marten) 

would be negatively affected. The construction of the linear corridor will reduce the size of 

some forested patches, which may affect habitat use by forest interior species. 

The linear corridor will be constructed in order to provide better access to Springpole Lake 

camp, therefore there will be some traffic on the road, which can cause disturbance to wildlife 

such as large mammals and furbearers. The level of disturbance will depend directly on traffic 

volume and speed. 

Mitigation 

The principle mitigation measures designed to reduce the potential adverse effects to large 

mammals and furbearers would be to restore the linear corridor to productive wildlife habitat 

upon closure. Traffic volume and speed will be quite low due to the fact that use of the road will 

be restricted to few trips per day. 

Significance 

The overall magnitude of the potential effects is considered to be minimal as the amount of 

habitat that would be disturbed through Project activities is quite small. The potential 

environmental effects that may occur to large mammals and furbearer populations will be 

localized in geographical extent. Although the duration of the potential effects may be long-term 

(~20 years), they are finite and reversible. Overall, the potential impacts from habitat loss, 

fragmentation and disturbance can be considered to be negative. 



similar in terms of the magnitude, duration and reversibility. Option A covers a larger geographic 

extent, but the difference in overall total habitat affected is negligible. 

Woodland Caribou 

Woodland caribou occur at low densities across most of their range in Canada (Schaefer 2003) 

and have been listed as a threatened species provincially and federally. Currently, caribou 

habitat is not regulated under the Endangered Species Act (ESA), aside from being given




general habitat protection. A general caribou habitat description will come into effect as of June 

30, 2013. The ESA prohibits the killing, harming, and harassing of caribou (Section 9(1), and 

prohibits damaging or destroying critical habitats that caribou rely on (directly or indirectly) to 

carry out their life processes (section 10(1). However, the Minister has the ability to issue a 

permit under section 17 of the ESA which allows a person to engage in activities prohibited by 

sections 9 and 10. Specifically, if the activity does not have the purpose of assisting in the 

protection or recovery of the species, but through specific conditions will result in an Overall 

Benefit (OB) to the species, a permit can be issued under section 17(2)c of the ESA. 

The MNR released the Ontario Recovery Strategy for Woodland Caribou in August 2008, which 

outlines recommendations for habitat protection. In 2012, Environment Canada released their 

Draft Recovery Strategy for Woodland Caribou (Rangifer tarandus caribou) Boreal Population, 

in Canada. Both documents provide provisions for industrial activities within caribou range 

provided they are consistent with caribou recovery strategies, and appropriate mitigation 

approaches are in place to minimize potential adverse effects. Caribou management in Ontario 

also follows the direction provided in the Cervid Ecological Framework (OMNR 2009b). The 

term “cervid” is used to describe any member of the deer family including caribou, moose, 

white-tailed deer and elk. The Cervid Ecological Framework (CEF) provides policy advice for 

broad, landscape-level management of cervids in relation to each other in the broader context of 

the ecosystems they share (OMNR 2009b). 

The Project is located within the north end of the Churchill Caribou Range (CCR) in 

northwestern Ontario. An initial Cumulative Effects Assessment and Proposal Screening Report 

of the CCR has been completed by the OMNR with the CST. This range assessment 

determined the current level of natural and anthropogenic disturbance within the range, as well 

as the amount and arrangement of suitable and future caribou habitat. A range is considered to 

have a higher probability of observing stable or positive growth of caribou populations if the total 

amount of disturbance (natural and anthropogenic combined) is less than 35% of the total 

range. 

The CST analysis indicates that the CCR is at moderate risk, owing to a total disturbance level 

of 38%. Anthropogenic disturbance in the CCR accounts for 34.5% of the total, while Natural 

disturbances account for 3.5% (Table 3.2.1). In order for the CCR to be considered a low risk 

range (




Environmental Effects and Mitigation 

Literature suggests that linear corridors (e.g. roads, transmission lines, seismic lines, etc) can 

have an adverse effect on caribou populations (Leblond et al. 2011, Weir et al 2006, James and 

Stuart-Smith 2000), as they facilitate access to caribou habitat by predators, which in turn 

increases predation. Caribou have exhibited avoidance of linear developments resulting in the 

functional loss of suitable habitat (Latham et al. 2011). Wolves in particular are known to use 

linear corridors in order to increase their access to prey populations (Latham et al. 2011). 

Caribou Collar Data 

An investigation of caribou use of the landscape was completed through an analysis of caribou 

collar data provided by the MNR in order to help determine the potential impacts to caribou and 

caribou habitat, mitigation and avoidance strategies and the resulting residual impacts that 

would cause the need for an Overall Benefits permit. Collar locations were separated into 5 

seasons as determined by Ferguson and Elkie (2004) (Table 3.5.1). After the collar location 

data were separated into seasons, an investigation was conducted in order to determine what 

areas of the proposed road corridor had the potential to cause negative environmental effects to 

caribou. 

Table 3.5.1 Dates of caribou seasonal movement patterns for analysis (from Ferguson and Elkie 

2004). 

Season 

Date Range 

1 (Late Winter) January 21 - March 5 

2 (Spring) March 6 - May 6 

3 (Calving) May 7 - July 14 

4 ( Post-calving) July 15 - November 14 

5 (Early Winter) November 15 - January 20 

The area around Springpole Lake has been recognized as a caribou wintering area, as well as 

an area which has provided caribou calving locations in the past. The determination of this use 

by caribou was derived from a combination of visual observations as well as caribou collar 

locations. Historical visual observations were made primarily in relation to wintering activity due 

to the fact that caribou and caribou tracks are more visible during the winter months. Recent 

GPS collar location data has revealed areas of seasonal use by caribou within the past year. In 

a landscape scale context, none of the collared caribou were found in close proximity to the 

potential road corridors during winter (early and/or late winter), but were found throughout the 

proposed road corridor area during spring, calving and post-calving. The OMNR has also 

observed caribou on the western side of Durkin Lake in the winter. 

Late Winter 

The area to the north of the eastern arm of Springpole Lake, and immediately south of 

Springpole Lake are considered caribou wintering areas, as evidenced by the historical 

sightings of caribou during the winter. The current functionality of this area to provide winter




habitat is questionable based on the fact that a large fire burned this area in 2011. According to 

the caribou collar data, none of the collared caribou used this area during late winter, but some 

animals did use the fringe of the burned area in early winter following the fire of 2011. At least 

four of the collared animals congregated in a wintering area between Okanse Lake and Perrigo 

Lake. Caribou also spent late winter east of Fawcett Lake and west of Snelgrove Lake. The 

construction of road Option A is not expected to have any negative environmental effect on any 

of these late wintering areas. 

Spring 

During the spring season, the collared caribou disbursed throughout the study area and were 

found in a wide variety of habitat types including the area burned in 2011. Of the collared 

animals in the study area, 3 were located in close proximity (5 km) to the proposed road Option 

A. One collared animal was found in the Dead Dog Lake area, another on the north and south 

shores of the eastern end of Springpole arm, and a third animal was found between Springpole 

Lake and Dole Lake near the Springpole camp. 

The construction of Road Option A could negatively affect caribou in two ways; through sensory 

disturbance; and increased predation risk. Sensory disturbance will be mitigated by enforcing 

strict timing restrictions on the use of the road during the spring period. For the most part, traffic 

will be eliminated during spring, with the exception of medical or other emergency use. 

Predation by wolves and black bears is considered to be the proximate cause of caribou 

mortality, particularly on calves (Lambert et al. 2006), with the majority of mortality events 

occurring in late winter. In order to reduce predation risk to caribou, alternate prey populations in 

the area need to be kept to a minimum. Wolves are known to be moose specialists, taking 

caribou opportunistically, therefore, by reducing favourable habitat for moose in an area, the 

likelihood of increased predation risk for caribou should be lowered. Moose populations will be 

kept to a minimum by reducing the amount of area converted to early successional vegetation 

and developing a vegetation management plan for the road corridor in consultation with the 

OMNR. 

Calving/Post-calving 

Caribou calving and post-calving seasons are considered critical times for caribou as calves can 

be highly susceptible to predation and maternal females can exhibit a lower tolerance for 

disturbance than other times of the year. The caribou collar data for the study area clearly 

shows animals disbursing from each other and spacing out during calving. With regard to the 

proposed road corridor (Option A), two collared animals spent the calving season in close 

proximity, with one female splitting the calving season between Dead Dog Lake and Fawcett 

Lake, and another female spending the calving season on the south and north shores of the 

eastern arm of Springpole Lake. 

Long-term, objective studies of the effects of development on calving caribou are rare due to the 

difficulty of obtaining data, costs and long timelines required to fully understand potential effects. 

In one study of a caribou calving ground in Alaska (Dau and Cameron 1986), the number of




calving caribou were surveyed for a four year period pre- and post- development of a road. The 

development of the road was found to have a statistically significant effect on calving caribou, 

resulting in fewer calving caribou being found near the road after construction than before 

construction. The degree of use by caribou of the areas adjacent to the road after construction 

was found to vary depending on the amount of human use of the road. Despite the lowered 

degree of usage of areas adjacent to the road, the overall number of caribou in the area and 

overall calving rate remained relatively constant. The study goes on to suggest that the low 

density of caribou on the calving grounds allowed for the use of alternative calving areas. 

However, other studies have shown that caribou mortality increases in close proximity to linear 

corridors due to increased encounter rates between wolves and caribou (James and Smith 

2000). 

Once all of the caribou habitat information and caribou location data was considered in relation 

to the potential road corridors, it was determined that there were two specific locations that had 

the potential to negatively impact caribou. These locations were at Dead Dog Lake 

(calving/post-calving), and in the area north of the eastern arm of Springpole Lake (winter, 

calving/post-calving). Caribou collar data revealed that Dead Dog Lake had been used as a 

calving lake during 2012. In order to avoid any negative impact to this calving area, the eastern 

road corridor was shifted further east, away from the lake. The area to the north of the eastern 

arm of Springpole Lake was also used as a calving/post-calving area by a collared caribou in 

2012. The options for avoiding the negative impacts to this area through road location are 

limited due to the fact that there are limited options with regard to road placement in this 

location. The road must extend from the eastern end of Springpole Lake to the current location 

of the exploration camp at the northern end of Springpole Lake, thereby, requiring the road to 

traverse through the calving/post-calving area. Additional mitigation strategies for both areas 

would involve road building in the winter to reduce disturbance during calving, restricted use of 

the road, signage regarding low rates of speed in the area, and following all MNR best 

management practices. 

Early Winter 

As previously mentioned, the area immediately south of Springpole Lake is considered a 

caribou wintering area, as evidenced by the historical sightings of caribou in that area during the 

winter. The current functionality of this area to provide winter habitat is questionable based on 

the fact that a large fire burned this area in 2011. According to the caribou collar data, none of 

the collared caribou used this area during early winter following the fire of 2011. At least four of 

the collared animals spent time in the RSA during early winter, however, no collared animals 

were within 15 km of Road Option A. The construction of road Option A is not expected to have 

any negative environmental effect on any of these early wintering areas. 

The following sections outline further determination of potential environmental effects to caribou 

following the Interim Policy Guidance for Assessing Development Proposals in the Continuous 

Distribution for Caribou in Ontario (OMNR 2012). For the purposes of this report, the 

“development proposal” in question refers to the construction and use of a winter road extending




from the current terminus of the Wenasaga road and extending northward to the Springpole 

camp. As per the guidance document, the mitigation of potential effects are discussed over 

multiple scales (ranges, seasonal ranges, high use areas, and calving sites) utilizing the 

following pre-determined assessment principles: 

1. Manage cumulative disturbance within the Range by minimizing the anthropogenic 

disturbance footprint 

The range assessment determined that the CCR already exceeds the “low risk” threshold of 

35% disturbance (Table 3.5.2). The construction of a road corridor will add to this measure of 

disturbance, however, the disturbance caused by either road option will have a negligible (i.e. 




Table 3.5.2 Comparison of disturbance statistics between road options A and B for the Churchill 

Caribou Range. 

Criteria Option A Option B 

Proposal Specific Statistics and Detail Sheet 

Churchill Range Specific Disturbance Statistics (Disturbance State) 

Beginning of 2011 

Natural 82,745 ha 4% 82,745 ha 4% 

Anthropogenic 733,978 ha 35% 733,978 ha 35% 

All Disturbance 816,723 ha 38% 816,723 ha 38% 

Range with Proposal 

Natural 82,587 ha 4% 82,216 ha 4% 

Anthropogenic 737,855 ha 35% 735,506 ha 35% 

All Disturbance 820,443 ha 39% 817,722 ha 38% 

Note: from the Cumulative Effects Assesment and Proposal Screening Report (CST-EOI-2012-0801-19/20) 

2. Manage habitat amount within the Range by minimizing functional habitat loss (i.e. via habitat 

change or conversion) 

The conversion of caribou habitat to habitat which is more favourable to alternate prey (moose 

or deer) is not likely to occur through the construction of a road corridor. Some caribou winter 

habitat patches will be eliminated (discussed later in this document), but these areas will be 

rehabilitated to their previous states upon closure. As previously mentioned, vegetation 

management and regeneration planning will be developed in consultation with the OMNR. 

Functional habitat loss, which results from the conversion of suitable habitat to non-suitable 

habitat, will be minimized by keeping all disturbance footprints to a minimum. The overall level 

of habitat that would be affected is relatively small compared to forest harvesting on crown land 

and is therefore fairly insignificant at the range scale (as evidenced through the CST analysis). 

The CST report showed winter habitat losses of 45 ha and 14 ha for Options A and B 

respectively (Table 3.5.3), however, the CST report was unable to take the 2011 wildfire into 

consideration in its analysis. Once the 2011 wildfire is taken into consideration the incremental 

winter habitat loss is reduced to 21 ha for Option A and 13 ha for Option B. Table 3.5.4 presents 

the amount, by patch size, of winter caribou habitat that would be directly affected through the 

construction of each corridor option. Caribou winter habitat patches were modelled through the 

OLT in order to determine the amount and arrangement of habitat patches in the following size 

categories: 1-100 ha, 101-250 ha, 251-500 ha, 501-1000 ha, 1001-5000 ha, 5001-10,000 ha, 

10,001-20,000 ha, and >20,000 ha (Figure 3.2). Habitat patches were modelled for the entire 

Trout Lake Forest and for the RSA (Table 3.5.5 and 3.5.6). The OLT results indicate that the 

amount of winter habitat patches within the Trout Lake Forest and the RSA are comparable. 

The minimum patch size that is utilized by caribou is debatable; however, most studies indicate 

that larger, more contiguous patches are preferred. Therefore, for the purposes of this analysis, 

the winter patches of 10,000 ha and greater were considered the highest quality patches within 

the RSA. It is worth noting that the 2011 wildfire eliminated 31,508 ha (23.35%) of winter habitat




patches from the >20,000 ha category from within the RSA. The portion of forest that was 

burned surrounds the entire southern half of corridor Option A (Figure 3.2). 

Table 3.5.3 Comparison of habitat statistics between road options A and B for the Churchill 

Caribou Range. 


Churchill Range Specific Habitat Statistics 

Winter Habitat 


Amount of winter habitat in range: 877,966.00 ha 877,966.00 ha 

Pending Proposal Queue (not including current proposal) 

Amount of winter habitat in recently disturbed queue 0.00 ha 0.00 ha 

Current Proposal 

Amount of winter habitat disturbed in this proposal 45.00 ha 14.00 ha 

Refuge Habitat 


Amount of refuge habitat in range: 1,071,183.00 ha 1,071,183.00 ha 


Amoung of refuge habitat recently disturbed and in queue 0.00 ha 0.00 ha 


Amoung of refuge habitat disturbed in this proposal 51.88 ha 18.31 ha 

Young Forest and Permanent Disturbance (YFPD) 


Amount of YFPD in range: 354,433.00 ha 354,433.00 ha 


Amount of YFPD recently created and in queue 0.00 ha 0.00 ha 


Amount of YFPD that would be created with this proposal 60.36 ha 26.21 ha 


The CST indicates that 60.36 ha and 26.21 ha of young forest and permanent disturbance 

(YFPD) would be created through the construction of Option A and B respectively. However, it is 

worth mentioning that the CST did not take the 2011 wildfire into consideration when calculating 

this value. If the wildfire is considered in the analysis, this would reduce the additional YFPD 

associated with Option A by 31.5 ha, bringing the total YFPD for this option to 28.86 ha.




Table 3.5.4 Total area (ha) of caribou winter habitat patches potentially affected by each road 

corridor option. 

Patch Size Option A (ha) Option B (ha) 

1-100 ha 0.04 5.81 

101-250 ha 0.00 0.00 

251-500 ha 0.55 0.00 

501-1000 ha 0.00 0.00 

1001-5000 ha 0.00 0.00 

5001-10000 ha 1.51 0.00 

10001-20000 ha 17.99 0.00 

>20000 ha 0.65 7.56 

Table 3.5.5 Total area of caribou winter habitat patches within the Trout Lake Forest and the 

RSA pre-, and post-2011 wildfire. 

Pre-2011 Wildfire 

Post-2011 Wildfire 

Patch Size Area within 

RSA (ha) 

Area within Trout 

Lake Forest (ha) 

Area within 

RSA (ha) 

Area within Trout 

Lake Forest (ha) 

1-100 ha 9,394 36,697 8,761 36,065 

101-250 ha 3,668 12,129 3,529 8,600 

251-500 ha 1,563 9,256 1,236 8,929 

501-1000 ha 3,005 14,407 3,004 14,406 

1001-5000 ha 5,142 18,453 5,124 18,434 

5001-10000 ha 13,776 31,535 13,655 31,414 

10001-20000 ha 14,997 18,164 14,960 18,127 

>20000 ha 83,982 241,313 52,474 209,805 

Table 3.56 Percent of total area of caribou winter habitat patches within the Trout Lake Forest 

and the RSA pre-, and post-2011 wildfire. 

Pre-2011 Wildfire 

Post-2011 Wildfire 

Patch Size % Area within % Area within Trout % Area within % Area within Trout 

RSA Lake Forest RSA Lake Forest 

1-100 ha 6.93 3.50 6.46 3.44 

101-250 ha 2.71 1.16 2.60 0.82 

251-500 ha 1.15 0.88 0.91 0.85 

501-1000 ha 2.22 1.37 2.22 1.37 

1001-5000 ha 3.79 1.76 3.78 1.76 

5001-10000 ha 10.16 3.01 10.08 3.00 

10001-20000 ha 11.07 1.73 11.04 1.73 

>20000 ha 61.97 23.01 38.72 20.01




3. Manage habitat arrangement and connectivity within the Range by minimizing fragmentation 

of refuge and winter habitat by linear features and other disturbances 

Connectivity of habitat will be maintained by placing corridors outside caribou habitat, or near 

the edges of caribou habitat where possible. The northern portion of road Option A will utilize 

portions of a pre-existing exploration trail, thereby reducing the degree of fragmentation in this 

wintering area. The area immediately south and east of Springpole Lake has also traditionally 

been used as a wintering area. A large fire in 2011 burned a significant portion of the landscape 

south of Springpole Lake and Seagraves Lake, effectively eliminating its current suitability as a 

wintering area. Despite being historically used as wintering area, caribou collar data showed 

that the burned area south of Springpole Lake was avoided by collared caribou throughout the 

late winter of 2012. The burned area will eventually track back to suitable winter caribou habitat, 

however, this will likely take upwards of 40 years to occur. This area was designated as a “Cblock” 

in the dynamic caribou harvesting schedule (due to be harvested in 2039-2059). After the 

Birch River crossing, corridor Option A skirts around the eastern end of Springpole Lake through 

the edge of a “D-block”, due to be harvested in 2059-2079. The portion of the corridor through 

the “D-block” would not fragment this habitat as it is located at the extreme west end of the 

mosaic. The northern portion of corridor Option A then goes through a “B-block”, due for harvest 

in 2019-2039. This portion of the corridor would fragment the southern portion of the “B-block”, 

however, this area is scheduled for harvesting in the next 7 to 27 years. It is anticipated that 

harvesting operations would begin in the southern portion of the “B-block” where the road is 

situated and progress northward throughout the next 20 years. Conversely, corridor Option B is 

located within an “A-block” (due to be harvested in 2009-2019), an “E-block” (due to be 

harvested in 2079-2099), then into the same “B-block” as corridor option A. 

The 2012 caribou collar data clearly shows individuals utilizing seasonally different and distinct 

portions of the study area throughout the year. Movement between these seasonal areas of 

concentration may potentially be negatively affected through the construction of a road corridor. 

The current collar location data indicates that corridor Option A has the potential to affect 

movement from calving areas to post calving areas near Dead Dog Lake and on the north shore 

of Springpole Lake. Negative effects of the corridor construction can be reduced by avoiding 

use of the road during critical times (calving and post calving), not plowing the road in the winter 

when it is not being used (to reduce potential suitability for wolves), and restricting traffic speeds 

and usage. 

4. Avoid increases in predator efficiency (i.e. distribution, ease of travel) by minimizing the 

density of linear features 

The “provision of access” has been designated as a key strategy necessary to meet the 

objectives of the current Trout Lake FMP. In support of this strategy a road construction 

program was designed within the FMP to allow for forest access as well as minimizing conflicts 

with other users. The goal of the general road strategy presented in the FMP is to reduce the




opportunity for predators of caribou to utilize roads once they are no longer needed for forestry 

operations. 

An FMP approved road corridor exists from Dead Dog Lake to within 1 km of the Birch River, 

which is planned for construction as early as 2014 (scheduling is currently in progress). This 

FMP corridor is planned for use as the southern portion of road Option A, and cannot be utilized 

in conjunction with Road Option B. According to the Trout Lake FMP, the Wenasaga road 

extension is planned to occur at some point before 2019, to a point extending northeast of 

Springpole Lake. Option B would provide a shorter access road to the Springpole camp, 

however, this corridor would be built in addition to the Wenasaga road extension, thereby 

increasing the density of linear features in the area. Also, if any interested party wished to utilize 

the chosen road option in the future, Option B would require the user to access GCU’s property, 

whereas, Option A would allow for use without the aforementioned access. 

Five road use strategies (RUS) have been developed for the Trout Lake Forest, for existing 

roads as well as new roads. These RUS’s identify the type of road maintenance, how 

monitoring will be carried out, intent of SFL to transfer road responsibility to MNR, MNR’s 

decommissioning provisions prior to transfer, and access restrictions. 

The Wenasaga Road extension has an RUS-3, which means that access will be restricted by 

signage as a condition of the FMP and the SFL holder will retain the road. The repercussions of 

this designation are that if Option A was constructed and the SFL holder wished to use the road, 

it would be unlikely to be decommissioned. This would result in GCU only being able to 

decommission portions of the road that were not considered needed by the SFL holder. 

Additional mitigative measures to reduce predator ease of travel is to create bends in the road 

reducing line of sight and to not plow the road in the winter, when possible, to make predator 

travel more difficult. 

5. Avoid increases in the distribution and productivity of other prey species (i.e. moose, deer) by 

minimizing the conversion of habitat (i.e. increased browse, hardwood) in disturbed areas 

An increase in the distribution and productivity of other prey species (i.e. moose and deer) 

would have a detrimental effect on caribou populations. Vegetation removal results in increased 

early successional vegetation which is favourable to other ungulates such as moose and deer. 

Increases in moose populations (alternate prey) can result in increases to predator populations, 

causing an increase in predation of caribou. Predation by wolves and black bears is considered 

to be the proximate cause of caribou mortality, particularly on calves (Bergerud 1974, Seip 

1992, Lambert et al. 2006), which is ultimately facilitated by habitat alteration (Briand et al. 

2009). Moose and deer populations in this area are inherently low, with only a few deer being 

seen in the last two years during field investigations. The amount of habitat alteration that could 

potentially occur with the construction of either corridor option would be negligible, particularly 

compared to the large-scale habitat conversions that occur through forestry practices. Corridor




construction would result in areas with little to no vegetation, as opposed to creating areas of 

vegetation favourable to ungulates other than caribou. The only areas associated with road 

construction which could become more favourable to alternate prey species would be the edges 

of the corridor. Corridor edges can support prolific early successional species favoured by 

moose and deer. In order to minimize the conversion of habitats to those that are more 

favourable to moose and deer, the overall area of disturbance will be kept to a minimum and a 

vegetation management plan for road corridor edges and harvested areas will be discussed with 

the OMNR. 

6. Avoid reduced use or avoidance by caribou near high use areas and calving sites by 

minimizing habitat/sensory disturbance (i.e. traffic, noise, etc) 

The OMNR range assessment reports indicate that the closest caribou nursery areas are within 

500 m of both Option A and B (Table 3.5.7). Table 3.5.7 also presents information regarding 

proximity to nursery points (caribou observations occurring between May 1 and September 15) 

and potential calving Lakes (it is worth noting that the information in table 3.5.7 did not take into 

consideration caribou collaring data from 2012, as it was unavailable when the analysis was 

conducted). According to the range reports, Option A was closer to more nursery points and 

potential calving Lakes than Option B. However, NRVIS data provided by the OMNR indicates 

three lakes in close proximity to corridor Option B are calving and/or nursery areas and one 

Lake close to Option A is a calving and/or nursery area (Figure 4.3). The area around Ruddy 

Lake was burned in 2011, therefore, the current suitability of this Lake for calving is unknown. 

DST conducted caribou calving/nursery area surveys, as per the OMNR protocol, to determine 

caribou use of lakes in close proximity to corridor Option A including; Dead Dog Lake, Seagrave 

Lake, Skingle Lake, Durkin Lake and Springpole Lake. The areas around Dead Dog and Skingle 

Lakes were both burned in 2011, reducing their current suitability as calving/nursery areas. 

Skingle Lake showed no signs of calving or nursery use, but fresh tracks were found on Dead 

Dog Lake, indicating that it may have been used as a calving/nursery area in 2012. The caribou 

collar data shows one female caribou spending a significant amount of time during the 

calving/post-calving periods on the same island in Dead Dog Lake where tracks were found. 

Portions of the area around Seagrave were also burned in 2011 and evidence of calving and/or 

nursery use was found in some of the unburned portions. The burned areas within the study 

area are currently unsuitable for calving/nursery areas, however, they will likely become suitable 

again through succession in 40 – 60 years. 

The potential adverse effects of the linear corridor on caribou calving would be those associated 

with increased predation and habitat/sensory disturbance. Caribou are known to exhibit site 

fidelity, particularly in relation to calving areas. Caribou have also been known to reduce their 

use of areas due to sensitivity to development. Linear corridors can indirectly impact the 

population by increasing predator access to the range and by creating physical or behavioural 

barriers to movement (habitat disturbance). In some cases habituation seems to be possible, 

but there are also documented cases of increased stress from fast moving vehicles, disruption 

of migration routes and displacement of maternal females from calving areas resulting in habitat




abandonment and decreased caribou density (sensory disturbance) (Webster 1997). Nelleman 

and Cameron (1996) found that access and use of calving habitat was restricted through the 

avoidance of roads and production related facilities. Ungulate habituation to road traffic is 

possible, but appears dependent on the degree of previous harassment and the amount of 

alternate habitat available (MacArthur et al. 1982). 

Table 3.5.7 Comparison of nursery/calving statistics between road options A and B for the 

Churchill Caribou Range. 


Proposal Specific Caribou Statistics 

Southern Range Statistics 

Proximity to Southern Range 

Minimum Distance 92.00 km 86.00 km 

Proximity to Nursery Areas 

Closest known nursery is within: < 500 m < 500 m 

Impact Counts: # of Nursery Areas: 

Within 10 km 5 2 



Proximity to Nursery Area Points 

Impact Counts: # of Nursery Area Points: 


Within 20 km 1589 221 

Within 50 km 4649 3541 

Proximity to High Potential Lakes for Calving 

Impact Counts 

Within 10 km 32 24 


Within 50 km 167 171 


To avoid reduced use or avoidance by caribou of high use areas such as calving and nursery 

sites, access corridors should be located as far away from calving locations as possible to avoid 

both habitat and sensory disturbance. Corridor construction is planned to take place in winter, 

which would eliminate construction disturbance during calving and shift it to a time when caribou 

are less susceptible to disturbance (winter). The CST report indicates Option B as having fewer 

calving/nursery areas in close proximity, however, Option B bisects a known calving/nursery 

area (Cook Lake and Bumpy Lake) and comes within a few hundred meters of both of those 

lakes, while the closest that Option A comes to a calving area is approximately 700 m (Dead 

Dog Lake). An additional strategy to prevent site avoidance is to keep traffic to a minimum or to 

restrict use during the calving period (i.e. May 15 to July 15) in order to reduce the amount of 

potential sensory disturbances. Reducing the amount of traffic utilizing the corridor during the 

summer is an option that is being considered in order to satisfy some stakeholder groups 

(primarily outfitters). This would also satisfy the requirements of lowering sensory disturbance 

levels for calving caribou. Use of the road during the critical calving period could be limited to 

medical and/or environmental emergencies. Johnson and Todd (1991) showed that as traffic 

increased in frequency, disruption of normal migration routes were likely to occur. The concept




of caribou harassment is very complex due to varying responses of caribou to human activities. 

Whether caribou are habituated to human presence or disturbance may also play a significant 

role in the resulting effects on a given caribou population. 

7. Avoid direct mortality of adults and calves (i.e. vehicle collisions, hunting) 

Access corridors have been shown to directly increase caribou mortality through vehicular 

collisions (Brown and Ross 1994). With the exception of First Nations, hunting caribou has been 

banned in Ontario since the 1930’s, and although poaching still occurs, gauging the amount of 

poaching that occurs is difficult. Alberta and British Columbia have had some success in 

reducing caribou mortalities by vehicular collisions by reducing speed limits in key areas of 

caribou concentrations (West-central Caribou Landscape Planning Team 2006). To reduce the 

risk of mortality, traffic volumes and speed limits will be kept to a minimum and warning devices 

(i.e. deer whistles) could be installed on all vehicles. Use of the road will be restricted to a small 

number of trips per day. GCU is considering placing restrictions with regard to road use in order 

to satisfy concerns of local outfitters. GCU may also install monitored gates which would prevent 

any access beyond what is approved in the FMP. A haulage schedule devised in consultation 

with local outfitters would likely also benefit caribou, with reduced traffic during the calving 

season. 

Significance 

The overall significance of the potential net effects on woodland caribou depends on the specific 

impact being investigated. Most of the potential impacts can be considered to be low, due to the 

relative certainty of the effects and the ability to mitigate most of the outcomes, however some 

of the impacts will be considered to be high. The net effects on woodland caribou would differ 

between the two options. The potential environmental effects that may impact caribou 

populations will be localized in geographical extent. Although the duration of the potential effects 

may be long-term (~20 years), they are finite and reversible through rehabilitation. Option A and 

B are both located close to calving/nursery areas and within caribou wintering areas. The 

impacts to any calving/nursery habitat and therefore to the species, can be considered to be 

high. To mitigate these impacts, road Option A has been moved farther east to increase the 

distance between the corridor and the calving lake (Dead Dog Lake). If Option B is moved 

further west, away from the calving lakes it would then bisect a large wintering area. This would 

reduce the impact to calving/nursery habitat, but would then increase the impact to wintering 

habitat, thereby negating the mitigation effort. The northern portion of road Option A is located 

near a calving/nursery area and within a wintering area. Unfortunately, as previously stated, 

there are no options for mitigating these impacts, as this is the only reasonable route for road 

Option A. The impact to the calving/nursery habitat for the northern portion of Option A can be 

considered to be high and the impact to the wintering area can be considered to be lowmedium. 

Due to the fact that the impacts to caribou calving/nursery habitat and wintering habitat for the 

northern portion of Option A cannot be avoided, they are considered residual negative effects,




and as such, will require the completion of an Alternatives Assessment Form and an application 

for an Overall Benefits permit under section 9 and 10 of the ESA. 

Overall, the potential impacts from habitat loss, fragmentation and disturbance can be 

considered to be negative, but it is GCU’s hope these negative effects can be mitigated through 

consultation with the MNR, by taking precautions that would eliminate or lessen the negative 

effects and through the Overall Benefits permitting process. Some examples of mitigation efforts 

to further reduce negative impacts include restricting use of the road during seasons that are 

sensitive to caribou (summer), keeping speed limits and traffic to a minimum and rehabilitating 

several lengthy (~10 km) exploration trails on their property. 

Comparison of Effects 

Table 3.5.8 compares the two road corridor options with regard to the potential negative effects 

to caribou, and relies on a scoring system from 1 to 3 where a higher score represents a lower 

threat to caribou when compared to the alternative. Option A scored higher (lower potential 

negative impact) than Option B primarily due to its use of existing disturbances, ability to 

maintain lower linear corridor densities, and lower potential disturbance to known 

calving/nursery areas. Although the scoring system is somewhat subjective, these three 

environmental effects (existing disturbances, corridor densities and disturbance to high use 

areas) are where the two options showed the clearest differences in their potential impacts.




Table 3.5.8 Comparison of road corridor options in the Springpole Lake area with regard to environmental effects to caribou 

Environmental Effect 

Alternative 

Overall 

footprint 

Potential for 

habitat loss 

Potential for 

habitat 

fragmentation 

Contribution to 

linear feature 

density 

Potential for 

habitat 

conversion 

Potential effect 

on high use 

areas 

Potential for 

direct 

mortality 

Utilization of 

existing 

disturbances 

Total 

Score 

Option A 

68 ha, 43.04 

km 

Removes 20.74 

ha 

Fragments a 

winter patch, 

but that patch is 

due for 

harvesting in 

next 7 - 27 

years 

Aligns with 

future forestry 

access road, 

existing 

exploration 

trails, and 

potential FN 

community 

access road 

No habitat 

conversion 

expected 

Bisects 

calving/nursery 

area, bisects 

wintering area 

Potential for 

direct mortality 

very low 

Traverses 

through large 

burn and utilizes 

portions of 

existing 

exploration trails 

Score out of 3* 1 1 2 3 3 1 3 3 17 

Option B 39 ha, 26.14 km 

Removes 13.37 

ha 

Fragments a 

winter patch due 

for harvesting 

over the next 7 

years 

Does not align 

with any 

existing or 

future linear 

features 

No habitat 

conversion 

expected 

Bisects 

calving/nursery 

area, bisects 

wintering area 

Potential for 

direct mortality 

very low 

No utilization of 

existing 

disturbances 

Score out of 3* 2 2 2 1 3 1 3 1 15 

*Note: a higher score indicates a lower potential negative effect to caribou than the alternative




Wolverine 


Wolverine are currently listed as Threatened in Ontario. The range retraction of this species 

throughout Ontario has been attributed to anthropogenic disturbances such as forest harvesting. 

Wolverine are known to depend heavily on scavenging caribou carcasses, primarily in winter. 

Therefore, as caribou populations decline, so do wolverine populations. 

Wolverine are known to inhabit the forests of the study area. During an aerial survey of the 

study area in 2011 a set of wolverine tracks were found on Springpole Lake. No known 

wolverine den sites have been located during any field work within the RSA to date. 

There are a number of potential ways that the road corridor could affect wolverine including; 

mortality as a result of vehicle collisions, modification of behaviour, and habitat fragmentation 

and loss. 

Mitigation 

The principle mitigation measures designed to reduce the potential adverse effects on wolverine 

would be to restore the linear corridor to productive wildlife habitat upon closure. Traffic volume 

and speeds will be quite low due to the fact that use of the road will be restricted to few trips per 

day and the vehicles to be used on the road will primarily be Nodwells (or equivalent), which are 

inherently slow. Any measures instituted to reduce the environmental effects on caribou are 

expected to benefit wolverine as well. 

Significance 


habitat that would be disturbed is quite small. The potential environmental effects that may 

occur to wolverine populations will be localized in geographical extent. Although the duration of 

the potential effects may be long-term (~20 years), they are finite and reversible. Overall, the 

potential impacts from habitat loss, fragmentation and disturbance can be considered to be 

negative. 

Significant Wildlife Habitat 


Habitats of Seasonal Concentrations of Animals 

Winter deer yards 

There are no known winter deer yards within the RSA 

Late winter moose habitat - Late winter moose habitat is abundant throughout the study area 

and may be directly impacted by the construction of either road corridor. However, moose 

populations in this portion of the Trout Lake Forest are inherently low (0-0.2 per km 2 ) and the 

wildlife management objectives in this area focus on caribou (OMNR 2009b). With the




management focus on caribou, combined with the abundance of the late winter moose habitat, 

the significance of the potential environmental effects is low. Mitigation will involve avoiding 

moose wintering areas during access road construction where possible. 

Colonial bird nesting sites - The only colonial nesting birds located within the study area were 

Bonaparte’s gulls. There is little quantitative information on the effects of human activities on 

gulls, but Bonaparte’s gulls are considered to be intolerant of human activity (OMNR 2010), 

therefore the potential negative environmental effects are considered to be high. The effects of 

roads on Bonaparte’s gulls nesting is unknown, but the Stand and Site Guide (OMNR 2010) 

assumes disturbance will be similar to Great Blue Heron Rookeries, with roads affecting the 

location, size, and occupancy of colonies. Moreover, roads landings, and aggregate pits create 

large canopy gaps in forest surrounding nests. Significant colonial bird nesting sites are those 

that are the only known sites in the area, support several species of concern and have high 

numbers of species. Significant sites also have little disturbance, and a long history of use. 

Bonaparte’s gulls are not considered “at risk”, and are considered of moderate conservation 

concern. Therefore, the significance of the potential environmental effects on the nesting colony 

is considered to be low due to the fact that other nest sites occur throughout the area, the 

colony is in an area with moderate disturbance, and there are no species of concern or other 

known nesting species. Following the direction provided in the Stand and Site Guide (OMNR 

2010), a 150 m radius buffer will be maintained around the nesting colony to mitigate potential 

disturbance and allow for the retention of nesting habitat. The access road will be kept below 

the 20 m recommended maximum width in close proximity to the nesting colony site. 

Waterfowl stopover and staging areas - There are no known waterfowl stopover and staging 

areas within the RSA. 

Waterfowl nesting sites - A ring-necked duck nest was located near the Springpole camp. There 

are no species of waterfowl considered to be “at risk” in Canada or Ontario, however, ringnecked 

ducks are considered to be high priority for conservation planning (NAWMP 2004). 

There is very little information pertaining to the reactions of nesting waterfowl to road 

construction or the consequences of disturbance in general, but reactions are likely highlycontext 

specific (OMNR 2010). Ground nesting waterfowl such as ring-necked ducks tend not to 

flush from the nest until humans are very close (1-6m), therefore the Stand and Site Guide 

recommends a minimum of 10 m buffering distance of occupied nests (OMNR 2010). Potential 

nest sites for ring-necked duck are not considered rare within the RSA (grassy sites within 200 

m of water (OMNR 2010)). There is no evidence of nest fidelity in ring-necked ducks, nor does 

this site support large concentrations of nesting waterfowl, other species of conservation 

concern, or a variety of waterfowl species, therefore the significance of the potential 

environmental effects to nesting ring-necked ducks should be negligible and would require no 

mitigation.




Shorebird migratory stopover areas, Landbird Migratory stopover areas, Raptor winterfeeding 

and roosting areas, Turkey vulture summer roosting areas, Reptile hibernacula, Bat hibernacula 

- There are no known shorebird migratory stopover areas, landbird migratory stopover areas, 

raptor winterfeeding and roosting areas, turkey vulture summer roosting areas, reptile 

hibernacula, or bat hibernacula within the RSA. 

Rare Vegetation Communities or Specialized Habitats for Wildlife 

Old-growth or mature forest stands - The Significant Wildlife Habitat Technical Guide indicates 

that forest stands that are 120 year old or older (“old growth”), can be significant. However, the 

Guide refers to stands found in southern Ontario, which can be very rare. In the boreal forest, 

“old growth” stands are more abundant than in southern Ontario, but do still play a key role in 

maintaining ecological integrity. Forest stands of 120 years of age and older are harvested by 

forestry companies daily, therefore, it would be remiss to consider all stands of this age class as 

being significant. The more significant “old growth” stands are those comprised of rare species 

or on rare ecosites (i.e. black ash (Fraxinus nigra), or cedar swamps on very rich sites). None of 

these stands have been found to occur within the RSA, therefore the potential environmental 

effects are considered to be negligible and no mitigation is required. 

Moose calving areas - There are a number of moose calving sites located within the RSA, 

however none of them have the potential to be affected by the road corridor. Therefore, the 

significance of the potential environmental effects on moose calving areas should be negligible 

and would require no mitigation. 

Moose aquatic feeding areas (MAFAs) - Two MAFAs occur within the RSA, however neither of 

them have the potential to be affected by the road corridor. Therefore, the significance of the 

potential environmental effects on MAFAs should be negligible and would require no mitigation. 

Mineral licks - A mineral lick has been identified within the RSA, however it is located on an 

island in Springpole Lake and is therefore not at risk of being affected through any Project 

development. 

Mink, otter, marten and fisher denning sites - There are no known mink, otter or fisher denning 

sites within the RSA. 

Habitats of Species of Conservation Concern 

Table 3.6.1 lists all of the provincially rare (S1, S2, S3) species that have the potential to occur 

in the Springpole lake area. No habitat of the species listed in Table 3.6.1 was located during 

field investigations




Table 3.6.1 Provincially rare (S1, S2, S3) species with the potential to occur in the Springpole area (from the Significant Wildlife 

Habitat Technical Guide OMNR 2000)




Aquatic Resources 


Potential environmental effects to the aquatic resources (lakes, ponds and streams) within the 

RSA include alterations to the water yield, peak flows, water chemistry, and water temperature. 

Shade provided by shoreline forest has an important influence on the thermal regime in many 

streams. In contrast, shoreline forest provides shade for only a small portion of the surface of all 

but the smallest lakes and thus appears to have relatively little biologically significant effect on 

littoral water temperature and the thermal regime of lakes (OMNR 2010). The effects of 

harvesting and wildfire on water quality appear to be influenced by the extent of catchment 

disturbance (Carignan et al. 2000) and do not appear to be prevented by shoreline buffers. 

However, shoreline forest may influence other functional aspects of lake and stream 

ecosystems (OMNR 2010). 

Potential stream flow alterations may result from: 

• Increased surface run-off during storm events due the clearing of vegetation. The 

removal of vegetation is known to decrease the rate at which water infiltrates the soil and 

increases run-off volumes, making small streams/creeks more vulnerable to flooding 

during storm events. 

• Alteration of flow regimes caused by improperly installed culverts and addition of 

aggregates. Improperly constructed road crossings are known to increase erosion and 

gradients in downstream areas and can also impede flow with insufficient culvert size or 

when improperly installed. 

Alterations to lake, pond, and stream water quality may result from: 

• Elevated levels of Turbidity, Total Suspended Solids, and Conductivity due to increased 

levels of erosion and sedimentation caused by the removal of riparian vegetation. 

• Increased water temperatures during the summer months due the removal of riparian 

vegetation may increase the solar input to a stream causing water temperatures to 

increase above normal temperatures. Furthermore, increased levels of Total Suspended 

Solids caused by sedimentation and erosion also increase water temperatures as they 

retain more solar radiation. 

Destruction/Displacement of Fish Habitat may result from: 

• Improperly constructed road crossings will impede fish migration and alter substrate type 

due to changes in the flow regime. 

• Changes in water temperatures due to erosion and sedimentation will affect species that 

are not resilient to warmer temperatures. Increased sedimentation will also fill in pools 

and under-cut banks, as well as covering essential spawning habitats such as gravel 

and cobble shoals.




Mitigation 

Flow Alterations 

All of the waterbodies in the RSA which have the potential to be directly affected by road 

construction and/or forest harvesting were assessed for biological values in 2012. None of these 

waterbodies possessed aquatic communities or values that would designate them as having a 

High Potential Sensitivity to forest operations as determined in the Stand and Site Guide (2010). 

Therefore, to minimize the effects caused by forest harvesting, residual buffers will be left 

around all lakes, ponds, and streams, as recommended by the OMNR’s “Forest Management 

Guide for Conserving Biodiversity at the Stand and Site Scales” document (2010) pertaining to 

waterbodies with a Moderate Potential Sensitivity to forest operations (i.e. 30 to 90 m residual 

forest buffers). 

In order to avoid negative flow alterations, a highly experienced and respected professional 

engineer has provided recommendations on all work in/around water crossing installations, 

including a detailed work plan outlining culvert sizes and installation procedures, as well as 

erosion and sedimentation controls plans. 

Significance 


aquatic habitat that would be disturbed by the road construction and forest harvesting is quite 

small and easily mitigated by following MNR guidelines. The majority of the tributaries are 

intermittent in nature with the exception of the Birch River and Dead Dog Creek and all of the 

lakes and ponds. The potential environmental effects that may occur to aquatic fauna will be 

very localized in geographical extent. 

The overall magnitude of the potential effects to streams, lakes, and ponds within the proposed 

footprint is considered to be low. To ensure that the effects on aquatic systems are kept to a 

minimum, MNR guidelines regarding minimum buffer widths will be followed.




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Ecol. 76: 568-579.

APPENDIX 5 

FIELD REPORT FROM DST 

(DST, 2013B)

DST Consulting Engineers Inc. 

106 North Cumberland Street, Suite 100 

Thunder Bay ON, P7A 4M2 

Tel: 807-345-3620 

Fax: 807-344-4738 

www.dstgroup.com 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

OBJECTIVIES: 

The objectives of the aerial survey were to: 

1. Survey a portion of the Regional Study Area which covered the main 

proposed area of development and the two proposed road corridors, to 

determine what areas were being utilized by caribou and/or moose, as 

well as any other large mammals, in the winter. 

2. GPS locations of observed stick nests. 

METHODS: 

General methods for aerial survey: 

January 14, 2013: 

Fly 30 km long transects (east/west) spaced at 1 km intervals 

Document all observed tracks, sign and animals 

Record the age and sex (where possible) of observed animals, 

Document all observed stick nests 

• Traveled to Forest Helicopters (Kenora) 

• Flew transects (5 and ½ transects completed) 

January 15, 2013: 

• Continued flying transects (12 additional transects completed). 

• Picked up trail camera located in the south eastern bay of Springpole 

January 16, 2013: 

• Picked up trail camera located behind camp 

Edmonton Winnipeg Kenora Thunder Bay Sudbury Waterloo Ottawa 

Kingston 

1.0.0.2

Client Name 

DST Reference No.: Page - 2 - 

• Continued flying transects (completed 13 transects for a total of 29) 

• Finished transects and flew back to Kenora 

• Stayed overnight in Kenora 

January 17, 2013: 

• Drove back to Thunder Bay on the morning of the 17 th . 

RESULTS: 

A total of 29 transects were flown resulting in approximately 900 km 2 being 

surveyed over the course of three days. No caribou were sighted over the course 

of the survey, however, 128 moose were seen. Only 1 moose was recorded as 

“unknown age and sex”. All other moose were successfully aged and sexed. 

Two sets of caribou tracks were observed, but they were approximately 2 days old. 

One other possible set of caribou tracks were seen, however, due to their age, 

positive identification was not possible. 

Other tracks and animals that were observed included wolverine tracks, otters and 

otter tracks, rabbit tracks, marten tracks, fox tracks, lynx tracks and an unknown 

owl. All sightings were documented with waypoints with the exception of the fox 

and rabbit tracks. It is worth noting that no wolves or wolf tracks were seen during 

the survey. 

A total of 22 stick nests were observed and marked with a GPS coordinate. Nests 

were classified as either: a) osprey, b) eagle, or c) hawk/raven. Pictures were taken 

of some of the more impressive nests. 

Summary: In general, moose densities were much higher than expected and were 

primarily concentrated to the southwestern portion of the area surveyed. This area 

had a very high proportion of the young regenerating burns that were 

approximately 5-15 years old, and therefore provided very good winter moose 

browsing areas. There were some areas that can be considered “good” caribou 

habitat, but it wasn’t optimal (i.e. open and sparse jack pine/black spruce with 

lichen), it was primarily dense black spruce with little to no deciduous component. 

This type of habitat also makes it very hard to see caribou. The conditions for the 

survey were good (i.e. recent snow, good visibility) and despite the very cold 

temperatures (-40 with the windchill on the 16 th ) animals were visible and moving 

around.

APPENDIX 6 

RECOMMENDATION FROM EQUI- 

KNOX ENVIRONMENTAL 

REGARDING PROCESS FOR 

ASSESSING COMPENSATION TO 

PROXIMAL OUTFITTERS

Equi-Knox Environmental Inc. 

February 24, 2013 


c/o Darryl Boyd 

via email 

Following my discussions with some of the Tourist Operators, I am suggesting revisions to the September 20, 2013 plan I 

prepared by which Gold Canyon Resources would compensate any Tourist Operators (‘TOs’) that may be affected by the 

Wenesaga Road extension. 

Upon the recommendation of the Government of Ontario, Gold Canyon Resources Inc. ("GCU") has retained me, Knox 

M. Henry of Equi-Knox Environmental Inc., to act in my capacity as a neutral evaluator to assess the impact upon, and 

recommend a compensation methodology for any TOs who claim they will be affected by the winter road being 

proposed by GCU. It is my understanding that GCU wishes to be proactive regarding this matter, rather than adopting 

the alternative of doing nothing and forcing each TO to file a claim against GCU, in court, for damages. 

Domtar, in its 2014 to 2019 Forest Management Plan ("FMP"), received government approval to extend the Wenesaga 

Road by ~24 kilometres, commencing in 2014, to enable it to have access to its logging operations planned under its 

2014/2019 FMP. 

GCU is seeking approval from the relevant authorities to construct a mineral exploration winter road along the FMP road 

corridor and then extend this winter road by ~21 kilometres to the exploration site on Springpole Lake. Currently the 

only access to GCU's exploration site on Springpole Lake is by aircraft in summer, and by ice road in winter over Birch 

Lake. This limits access to the site both in frequency and in the type of materials that can be moved into the site. 

GCU seeks on its own behalf, to commence construction of the trail, within the FMP-approved road corridor, less than 

one year earlier than approved under Domtar's FMP. Further, as aforementioned, GCU seeks approval to extend the 

winter road, by approximately 21 kilometres, from the end of the FMP-approved road corridor to end at a point at its 

current GCU exploration area and tent camp on the north shore of Springpole Lake. 

In order to assess the potential economic impact upon the TOs, Mr. Henry has recommended that the TOs would be 

expected to provide, in confidence, information to substantiate their concerns and conclusions that the construction of 

this road extension would have a negative financial impact upon their businesses. Specifically, submissions from the TOs 

should include, but be not limited to the following: 

1. Copies of their submissions, if any, to the relevant authorities objecting to the original construction of Wenesaga 

Road by Domtar. 

2. Copies of their submissions, if any, to the relevant authorities objecting to Domtar's 2014/2019 FMP and the 

proposed extension of the Wenesaga Road within that FMP. 

3. Tax returns, or some similar documentation, from the past 10 years detailing: 

a. How the construction of the original Wenesaga Road by Domtar caused a downturn in their business. 

b. Marketing and advertising expenses by TO for each of their lodges to overcome the downturn in "a" above. 

c. The effect of weather and economic conditions on their businesses over the last 10 years. (Including, for 

example, how inclement weather might have negatively affected aircraft operations, etc.). 

d. the approximate number of days each of their respective lodges was in operation, per season, over the past 

10 years. 

4. Copies of their respective leases with the Crown. 

Upon receiving the above-noted information, Mr. Henry will then meet with each of the affected tourist operators and 

confidentially discuss with them their submissions and documentation, if any. All of the documentation provided by the 

1

TOs will remain in Mr. Henry’s possession and not disclosed to GCU or anyone else. This documentation and the content 

of Mr. Henry’s discussions with any TO, or other persons associated with any TO, will remain confidential and cannot be 

requested or divulged in any future proceeding. 

Following the submissions of the information from the TOs, and meetings, if any, with the TOs, he will then prepare a 

recommendation to GCU respecting any compensation due to the TOs. 

I trust this procedure meets with your approval, 

Yours sincerely, 

Knox M. Henry, 

President 

45 Smithy Street Suite 202 Markham ON Canada L3P 6M6 Tel.: 905.294.6196 Mobile: 416.587.5201 Fax: 905.294.6780 

HST No.: 81116 5455 RT0001 

2

APPENDIX 7 

7A: WATER CROSSINGS 

ENGINEERING REPORT AND SITE 

DATA

Water Crossings on the Proposed Springpole Road 

East of Red Lake, Gold Canyon Resources Inc. 

Introduction 

Gold Canyon Resources Inc. is a mining exploration company with an active drilling program on 

properties it holds near the west end of Springpole Lake. The drilling program is supported by a 

sixty person tent camp with cookhouse, sewage treatment plant, domestic water supply, core 

shacks, storage, dock, heli-pad and ancillary lay down areas. Access to the Springpole Camp is 

currently by helicopter, float plane and a seasonal ice road across Birch Lake to the north of the 

camp. 

It is projected that increased drilling activity and mine development will occur over the next few 

years and it is necessary to improve access to the Springpole Camp. An existing forest access 

road is located south of the camp (Wenasaga Road 82-6). It is proposed to build a forestry winter 

operational road from the existing road to the camp, a distance of about 40 km. At 18.2 km along 

this route is the Birch River, a large river crossing. It is proposed to build the Birch River Bridge to 

primary road standard in order to provide better protection of environment and to facilitate future 

upgrades to the road without impacting the river. For simplicity, the trail and future forest access 

road, will be referred to as Springpole Road. 

The MNR procedure for identifying water crossings on forest access roads has been followed on 

this project. Any creek or river mapped on 1:50,000 Federal series contour maps or on 1:20,000 

OBM Provincial maps is considered a water crossing. Furthermore, any un-mapped water course 

that has a defined channel without vegetative growth in it is also considered a water crossing. 

Adamson Consulting has been retained by Gold Canyon Resources Inc. to provide engineering 

design services related to the water crossings along the route of the proposed trail / road. 

Design Standards and Approvals 

Standards for water crossing design on Crown land have been established by MNR, DFO and 

Transport Canada (TC). They are contained in various documents referenced at the end of this 

report. In general, the following standards apply to this project: 

No bridge or culvert can cause the harmful alteration, disruption or destruction of fish 

habitat, unless authorized under the Fisheries Act. (DFO) 

 

 

 

 

 

The Crown Land Bridge Management Guidelines, 2008 must be adhered to. (MNR) 

The Operational Statement for Clear-Span Bridges, 2009 must be adhered to. (DFO) 

Bridges must clear span the channel defined by the ordinary high water mark. (DFO) 

Bridges must provide 2m vertical clearance above normal high water level and provide 6m 

horizontal clearance if the channel is used by motor boats. (TC) 

Bridges must provide 0.5m vertical clearance above the 25-flood level. (MNR) 

Water Crossing Report Adamson Consulting Page 1 of 14 

Springpole Road October 21, 2012

The 25-year flood (Q 25 ), determined by the MNR computer hydrology model, is the 

minimum flow for design of bridges and culverts. (MNR) 

Culvert diameter sizes are to be equal to, or larger than, those determined by the MNR 

computer hydrology model for Q 25 . (MNR) 

Culverts must not block fish migration, either by being perched or because flow velocity 

exceeds fish swimming ability (DFO). This is normally achieved by using the following 

rules: 

o Culverts are only suitable if the streambed slope is less than 2 percent. If the slope 

is between 1 and 2 percent, fish passage velocity should be determined by an 

engineer to confirm blockage will not result. Using a larger culvert or deeper 

embedment in the streambed are techniques used to reduce flow velocities. 

o The culvert invert (bottom) must be set at least 10 percent of its diameter below the 

streambed elevation. 

 

Culverts and bridges must be installed properly by competent people trained and 

experienced in this work. They should have the knowledge, skills, attitude and support 

necessary to ensure a satisfactory installation. (MNR & DFO) 

All water crossings must be constructed in compliance with a Work Permit issued by the MNR. 

Culvert water crossings must be submitted for review to DFO, who then issue a Letter of Advice 

with conditions to guide construction. Although DFO does not require pre-work approval of bridge 

proposals that meet the requirements of the Operational Statement, they do require a completed 

Notification Form in case they want to make an inspection. 

An application for approval under the Navigable Waters Protection Act is required by Transport 

Canada for bridges proposed to be built over navigable waters. 

Stream Simulation Design Method 

“Stream simulation is an approach to designing crossing structures (usually culverts), that creates 

a structure that is as similar as possible to the natural channel. When channel dimensions, slope 

and streambed structure are similar, water velocities and depths also will be similar. Thus the 

simulated channel should present no more of an obstacle to aquatic animals than the natural 

channel.” (US Forest Service) 

In meetings and in comments on the proposed water crossings for the Springpole Road, DFO 

(Tom Kleinboeck) has suggested the Stream Simulation Design method be considered. 

A clear span bridge, designed and constructed in accordance with DFO’s Operational Statement 

and installed on a stable stretch of channel, would satisfy this criteria. 

For small watersheds, particularly those less than 2 sq km drainage area, the use of bridges would 

be an unnecessarily conservative and expensive approach compared to properly designed and 

installed round culverts. The Stream Simulation Design Method allows for the use of round 

culverts, provided the final channel through the pipe simulates a stable stretch of the natural creek. 



Water Crossings Identified 

The route of the proposed trail / road was laid out and flagged in the field in April 2012 by Mr. Len 

Hercun. Mr. Hercun is an experienced forest worker responsible for access road layout on 

Domtar’s Trout Forest. A total of 14 water crossings were identified and recorded by Mr. Hercun. 

They fell into the following categories: 

Four crossings appear on the 1:50,000 maps – 

o #1, Deaddog Creek, Km 4.35 

o #7, Birch River, Km 18.21 

o #8, at the east end of Springpole Lake, Km 20.26 

o #14, near the camp, Km 38.47 

Three crossings appear on the 1:20,000 maps but not on the 1:50,000 maps (#4, 5 &, 9) 

 

Seven additional small unmapped crossings were identified in the field 

The water crossings are identified, along with Mr. Hercun’s field comments, in Table 1 – Water 

Crossing Locations. 

For each crossing, input parameters needed for the MNR hydrology program were determined 

from the 1:50,000 and 1:20,000 maps. During this analysis, online GoogleEarth photos and 

Mapsource Backroads Ontario digital mapping were used to help define the watersheds. The 

results of the hydrology analyses and culvert sizes determined using the MNR program are 

presented in Table 2 – Water Crossing Hydrology Results. 

Culvert Water Crossings 

The route of the proposed Springpole Road follows high ground and with two exceptions all of the 

water crossings are quite small (

All of the culvert sizes recommended in Table 2 can be successfully installed in winter, provided 

the MNR guidelines appended to this report are followed. It is recommended that the pipe wall 

thickness be 3.5mm, or preferably 4.2mm, for greater strength. 

The recommended culvert length is 13m to provide a 6m trail surface, 0.5m cover over the pipe 

and 1.75H:1V fill slope angles. When the trail is upgraded to a full-width forest access road the 

culvert can be extended with pipe sections and couplers without disturbing the previous 

installation. 

All culverts should be installed to comply with the MNR guidelines: 

CSP Culvert Installation at Water Crossings on Forest Access Roads, 1996 

Guidelines for Culverts Installed in Winter, 1996 

To achieve the design criterion of meeting engineering and fisheries objectives, it is important that 

the culverts be embedded at the correct elevation below the stream bottom; backfilled with 

compacted well-graded granular backfill material; have fill slopes trimmed to a stable angle; have 

rock rip rap around the pipe ends; and, have black muck and seed stabilization on fill slopes. 

With construction expected to occur in winter it will be difficult to identify some creek channels 

under snow cover. It is recommended that an experienced forest worker visit each culvert site 

before winter to confirm the channel widths are less than 1m and that streambed slopes are less 

than 1 percent. The exact culvert ends must be marked with stakes that will project above 

expected snow cover to avoid problems finding the channel. 

As a contingency, it is recommended that Gold Canyon Resources have available at least one 

portable bridge to install in case a culvert site proves unsuitable during construction of the trail (eg 

bedrock, or if the channel is wider than expected). A recommended design is shown on following 

drawing. It would be suitable as a clear span bridge for any of the 12 water crossings where 

culverts are planned. 

Drawing 1 of 1, Temporary Bridge - General Arrangement Drawing, Oct 14/12 

Deaddog Creek Bridge, Xing #1, Km 4.35 

The reach to be crossed is at the transition from a riffle section upstream to a meandering slow 

moving reach downstream (Photo 1). Channel width is approximately 4m. The author has not 

visited the site, however information has been provided by Len Hercun (laid out road alignment) 

and Kyle Emslie (DST fisheries biologist). It is proposed to install a permanent 30-foot bridge at 

this location. The channel is not considered navigable, therefore Transport Canada application 

and clearances are not expected to apply. 

The bridge is to be constructed in accordance with the following drawing: 

Drawing 1 of 1, Deaddog Creek Bridge, General Arrangement Drawing, Oct 13/12 

Construction of this crossing should be straight forward. As per the DFO Operational Statement for 

Clear Span Bridges, access to the far shore will be by making one return ford crossing. 



Birch River Bridge, Xing #7, Km 18.2 

It is proposed to cross Birch River with a clear span structure 120 feet long. A site visit was made 

on October 6, 2012, when flows were lower than average. From records at a downstream flow 

gauge station it was determined the flow at the time was 15 m 3 /sec, compared to the mean 

October flow of 20 m 3 /sec. During the visit a field survey was undertaken to provide data for bridge 

design. 

Project Design 

An hydrology analysis was completed following the MNR method. Another analysis was done 

using the Single Station Frequency Analysis Method, as set out in the MTO Drainage Management 

Manual, 1997. Within the same watershed, downstream of the bridge site, is the Water Survey of 

Canada flow gauge on the Cat River, below Wesleyan Lake (04GA002). Drainage area at the 

bridge site is 1366 km 2 and it is 5390 km 2 at the gauge. Forty-three years of record are available. 

The latter method resulted in a higher flood flow, so this is used for design. 

The proposed bridge is 36.58m (120’) long to clear span the channel. The bridge will be high 

enough to meet minimum vertical clearance requirements for floods and navigation. The proposed 

superstructure will be a modular truss bridge design. The bridge abutments will be located back 

from the water’s edge, therefore no permanent in-stream excavation or in-stream fill will be 

necessary. The bridge abutments will be treated timber cribs, similar to most bridges on forest 

access roads in Ontario. The design drawings for the project are: 

Drawing 1 of 2, General Arrangement Drawing, Adamson Consulting, Rev. 1, Oct 18/12 

Drawing 2 of 2, Bridge Abutment Construction Drawing, Adamson Consulting, Oct 15/12 

Construction Strategy 

At present, it is proposed to construct the Birch River Bridge in February or March of 2013. This is 

the open fisheries timing window when the risk to fish is lower. Access for construction will be 

along the new trail construction route. 

February and March are the months with the lowest flows and water levels during the year. 

Bridge construction will be carried out by a competent and experienced bridge contractor and Gold 

Canyon Resources will arrange to monitor construction and do a final inspection to confirm the 

bridge is built properly. Any significant problems or deviations from the drawings will be brought to 

the attention of the design engineer for advice. 

On the bedrock river banks rock excavation will be necessary to achieve satisfactory road grades 

and to found the crib abutments on level ground. The material removed will provide rock rip rap for 

erosion protection in bridge and culvert construction. 

Although the contractor has not been selected yet, in general terms the expected strategy is: 

1. Mobilize equipment and materials (incl. timber, steel superstructure, hardware, crib fill, ramp fill 

and rock rip rap materials) to the site by winter ice road over Springpole Lake from the camp to 

the outlet of Birch River from the lake. 



2. At present, the planned winter ice road would allow access to both sides of Birch River by trails 

from Springpole Lake. If all goes as planned, it shouldn’t be necessary to ford the river for 

construction. However, the fall-back plan in case of schedule delay or unseasonably warm 

weather, would be a one time ford (across and back) by the backhoe to the far shore, as 

permitted by DFO’s Operational Statement for Clear Span Bridges. Due to the steep 

approaches, the ford crossing may have to be at Site #1, approximately 200m upstream of the 

proposed bridge site. 

3. At each abutment location, the foundation area will be prepared by bedrock excavation and the 

crib abutment will be constructed to the bearing level. 

4. The approach ramp on the accessible west side will be constructed to bearing level. 

5. The steel superstructure will be installed by the cantilever launch method, from one side. 

6. The approach abutment and ramp will be completed to grade. 

7. The far side ramp will be constructed by end-dumping off the bridge and the far side crib 

abutment will be filled. 

8. The far side abutment will be completed to grade 

9. Rip rap erosion protection will be placed in front of the cribs and on the fill slopes. 

10. Final trimming and disposal of surplus materials will complete the project. The bridge will be 

inspected for compliance with design and approval conditions. 

References 

Crown Land Bridge Management Guidelines, MNR, 2008 

1 Stream Simulation: An Ecological Approach to Providing Passage for Aquatic Organisms at 

Road-Stream Crossings, US Forest Service, 2008 

1 Ontario Operational Statement for Clear Span Bridges, DFO, 2007 

CSP Culvert Installation at Water Crossings on Forest Access Roads, MNR, 1996 

1 Environmental Guidelines for Access Roads and Water Crossings, MNR, 1988 

1 available in PDF format on-line from the regulators’ websites 

This report was prepared for Gold Canyon Resources Inc., on October 21, 2012 by, 



Table 1 - Water Crossing Locations, Springpole Road, East of Red Lake, Gold Canyon Resources Inc. 

Crossing 

Number 

Shows on 

1:50,000 map? 

Shows on 

1:20,000 map? 

Km from 

start of trail 

Len Hercun & DST site comments Latitude & Longitude UTM Coordinates 

1, Deadog Yes Yes 4.35 4m wide & < 1m deep N51 14.345 W92 09.248 15 U 559048 5676753 

2 No No 7.80 Channel

Table 2 - Water Crossing Hydrology Results, Springpole Road, East of Red Lake, Gold Canyon Resources Inc. 

Crossing 

Number 

Drainage Area 

(km 2 ) 

Lake Area 

(km 2 ) 

Swamp Area 

(km 2 ) 

Watershed 

Slope (m/m) 

Q25 (m 3 /s) 

Q25 Culvert 

Size (mm dia.) 

Recommended 

Structure 

1, Deaddog 14.7 *2.94 0.0 0.0031 3.3 1600 30’ bridge 

2 0.3 0.0 0.045 0.015 0.5 800 1200mm culvert 

3 0.91 0.0 0.067 0.01 1.1 1000 1400mm culvert 

4 0.5 0.0 0.037 0.008 0.7 800 1200mm culvert 

5 0.7 0.0 0.09 0.007 0.8 1000 1400mm culvert 

6 0.8 0.0 0.042 0.008 1.0 1000 1400mm culvert 

7, Birch 1366 273 Not significant 0.00044 58.2 Not applicable 120’ bridge 

**8, East end of 

Springpole Lake 

0.8 0.1 0.007 0.008 0.6 800 1200mm culvert 

9 1.5 0.1 0.3 0.0047 0.8 900 1400mm culvert 

10 0.7 0.1 0.0 0.005 0.5 800 1200mm culvert 

11 0.07 0.0 0.0 0.008 0.2 500 1000mm culvert 

12 0.05 0.0 0.0 0.008 0.1 500 1000mm culvert 

13 0.11 0.0 0.0 0.008 0.3 600 1000mm culvert 

**14, near camp 0.7 0.08 0.01 0.008 0.6 800 1200mm culvert 

Notes: * Actual lake area is greater, however it has been limited to 20% of watershed area as per MNR procedure 

** Crossing location is currently under review and may change 



Map 1 – Water Crossings in Southern Portion of the Proposed Springpole Trail 



Map 2 – Water Crossings in Northern Portion of the Proposed Springpole Trail 



Photo 1: Deaddog Creek crossing site 

Photo 2: Birch River crossing site, looking west. Red flags mark proposed centerline. 



Photo 3 – Site #2 indicates proposed bridge location, Site #1 indicates ford location. 

Photo 4 – View of ford location at Site #1. 



MNR Guidelines For Culverts Installed in the Winter 

Winter culvert installations should be avoided if at all possible due to the difficulty in obtaining 

adequate backfill compaction. For this reason, winter installations are not recommended by the 

culvert supplier Armtec. Their studies have shown that "dry" backfill placed in winter will attain 

compaction in the 70 to 85% range. The normal minimum expected is 90%. Failure to attain 

backfill compaction can mean inadequate soil arch development resulting in pipe collapse or 

washout. This would prove costly to the builder and will harm the environment. 

The increased risk to fish habitat downstream of a winter installed culvert requires MNR to 

impose special guidelines. Adherence to these guidelines is no assurance the pipe installation 

will be successful. The onus is on the builder to ensure there is no harmful alteration, disruption 

or destruction to fish habitat at the site or downstream as a result of the work. 

These guidelines apply to water crossing culvert installations constructed between mid- 

November and the end of April, referred to as "winter". Approval conditions and environmental 

protection measures used for all culvert crossings also apply to winter installations. It is 

expected that proper culvert installation techniques, as recommended in Installation Manual 

available from MNR, will be followed. 

1. Maximum pipe diameter for winter installation is 1800 mm. Any proposal to install a 

larger size will require approval of the MNR Engineer. Approval will depend on 

satisfactory experience in installing large culverts and having a source of "dry" well-graded 

gravel material for backfill. 

2. The site must be visited by the applicant before snow covers the ground to assess site 

conditions and foundations. The pipe alignment and grade must be laid out before snow 

cover arrives. 

3. The backfill material must be a "dry" well graded gravel having a range of particle sizes 

from gravel to sand. Silt and clay content must be less than 10 percent. A low moisture 

content is required to minimize the formation of frozen lumps and to improve the chances 

of satisfactory placement. 

4. Backfill material must be hauled in trucks having heated boxes. Backfill material must not 

contain ice or frozen lumps. Backfill material is to be placed in thin layers, brought up 

evenly on both sides and compacted, similar to non-winter installations. 

5. The minimum thickness of pipes installed in the winter is 2.8 mm. 

6. Fill slopes are to be no steeper than 2H:1V and good quality rip rap material is to be placed 

around the pipe ends to protect the fill from erosion. 

...2 



- 2 - 

7. In the spring, when the frost is out of the ground, the pipe is to be inspected by a competent 

person familiar with MNR requirements. Significant settlement of the road fill beside the 

pipe or distortion of the pipe out of round by more than 10 percent is cause for concern. If 

either condition is observed, the backfill is to be removed to water level for a distance of 3 

metres on each side of the pipe and replaced in the normal manner, with compaction. Any 

sources of erosion that will cause sediment to enter the creek are to be treated to meet 

requirements of the work permit. 

8. The coupler can often be a weak link in culvert installations. If possible, a one piece 

culvert should be used as opposed to one that requires coupling (ie 1 x 18m vs 3 x 6 m). 

9. Snow cover can easily make one forgetful of the importance of constructing measures to 

control runoff water to prevent sediment. Attention must be paid to good diversion berms 

or off shoot ditches into the standing timber. 

10. Any potential settling of the culvert will usually be concentrated under the load of the 

backfill. Consequently, the ends of the culvert could have a tendency to "float up". The 

culvert ends should be weighted with cobble to promote even settling if any settling should 

occur. This material can be pulled back after spring thaw. 

11. A few loads of good backfill material placed handy to site will rarely go to waste. A 

stockpile will reduce the need for full mobilization of a construction crew if a deficiency is 

detected. If the stockpile is not needed for the crossing, it can be utilized to fix a soft spot 

on the road. 

RBA 1996 02 20 



CROSSING 1 - Dead Dog Crossing 

15 U 0559043 

5676749 

Crown Land Water Crossing Application Part 4 

Conducted on September 14, 2012 

Weather: Sunny, No precipitation, Light Wind 

Completed by 

Ashley Polson (Environmental Coordinator, Gold Canyon Resources) 

Comments: Completed with the assistance of Len Hercun. Len viewed the 

biologist’s proposed location and adapted it to 6.3m west to ensure road could be 

constructed with ease as a large bed rock hill was directly north of Bio’s position . I 

have included a site form for each location. 

NOTE: SITE DATA INCLUDED IN BRUCE ADAMSON ENGINEERING REPORT FOR DEADDOG 

1

Photo 1: Facing North at original flagged location 

Note: Orange flagging tap in middle location of photo. 

Over 20 meters from the Biologist’s and Len’s proposed crossing. 

2

Photo 2: Facing North at Biologist’s recommended flagged location 

Note: Blue flagging tap in middle location of photo. 

3

Photo 3: Facing East at Biologist’s recommended flagged location 

4

Photo 4: Facing South at Biologist’s recommended flagged location 

5

Photo 5: Facing West at Biologist’s recommended flagged location 

6

Photo 6: Facing North at Len’s New recommended flagged location. 

Note: Orange and black flagging tape on left side of picture is where Len Herc recommends road 

crossing. Blue flagging tape on right side of photo is where the biologist’s recommendation for 

crossing was. Distance between Biologists and Len’s recommendation is 6.3m. 

7

CROSSING 2 SPRINPOLE ROAD - SITE PICTURES TAKEN APRIL 2012 


STREAM SIMULATION CULVERT SIZE = 1200MM 

8



CREEK LOCATION 


9




10





11




12





13




14





15




16





17

CROSSING 7 - Birch River Crossing 

15 U 0565468 

5687242 

Crown Land Water Crossing Application Part 4 

Conducted on September 16, 2012 

Weather: Overcast, no precipitation, moderate wind 

Completed by 

Ashley Polson (Environmental Coordinator, Gold Canyon Resources) 

NOTE: SITE DATA INCLUDED IN BRUCE ADAMSON ENGINEERING REPORT FOR BIRCH R 

18

Photo 2: Taken facing the West on top of hill 

Note: Orange flagging tape on East side of stream (bottom of photo) and orange flagging on West 

side of river (slightly to the left of center). 

20

Photo 3: Taken facing the West on top of hill not on the top of the hill 

Note: Orange flagging tape on East side of stream (bottom of photo slightly to the left) and 

orange flagging on West side of river (slightly to the left of center). 

21

Photo 4: Taken facing North of East side flagging tape 

22

Photo 5: Taken facing South of East side flagging tape 

23

Photo 6: Directly at flagging tape facing West 

Note: Orange flagging tape on East side of stream (bottom left of photo) and orange flagging on 

West side of river (slightly to the higher then center). 

24

Photo 7: Taken facing the North approximately 20 feet south of flagging 

Note: Orange flagging tape on East side of stream (on right side of photo in line with center) 

25

Photo 8: Taken south on the east side approximately 10 feet from East side flagging 

26

CROSSING 8 SPRINPOLE ROAD ( EAST END SPRINGPOLE LK) - SITE PICTURES TAKEN APRIL 2012 



27

CROSSING 8 SPRINPOLE ROAD ( EAST END SPRINGPOLE LK) - SITE PICTURES TAKEN APRIL 2012 


28

CROSSING 9 SPRINPOLE ROAD ( EAST END SPRINGPOLE LAKE) - SITE PICTURES TAKEN APRIL 2012 



29

CROSSING 9 SPRINPOLE ROAD ( EAST END SPRINGPOLE LAKE) - SITE PICTURES TAKEN APRIL 2012 




30




31





32




33





34




35





36




37





38




CURRENT SITE PICTURES NOT AVAILABLE 

39

APPENDIX 7 

7B: BRIDGE CONSTRUCTION 

DETAILS

SENT BY E-MAIL ATTACHMENT 

Adamson Consulting 

The Water Crossing Specialist 

126 Prospect Ave. 

Thunder Bay, ON 

P7A 5L4 

(807) 345-7073 

adamsonb@shaw.ca 

October 18, 2012 


Suite 810, 609 Granville Street 

P.O. Box 10356, Pacific Centre 

Vancouver, BC, V7Y 1G5 

Attention: Mr. Darryl Boyd 

SUBJECT: 

Bridge Design Package for Deaddog Creek Bridge, Proposed Springpole Road 

As requested to accommodate DFO’s desire to avoid any constriction of the channels, we 

changed the proposed crossing structure for culverts to a bridge. I did not have the opportunity 

to visit the site, but have reviewed measurements, comments and photos provided by Len 

Hercun and Kyle Emslie. 

Then we completed a bridge design package suitable for you to submit to DFO and MNR for 

approvals. 

Attached are the following documents that make up the design package. 

Drawing 1 of 1, General Arrangement Drawing, Adamson Consulting, Oct 13/12 

Bridge Design Record Form, Oct 13/12 

Bridge Site Data Form, Oct 13/12 

Crib Round Summary, Oct 13/12 

Material Lists, Oct 13/12 

Please call if there are any questions or if we can be of further assistance. 

Yours truly, 

Bruce Adamson, P. Eng

Bridge Design Record Form 

Bridge Information Permanent Bridge Temporary Bridge 

Crossing No. 

River Crossing Name 

Deaddog Creek 

Bridge Contractor/Builder Name 

To be determined 

Standard Construction Drawings Used for Bridge: 

MNR Standard Bridge Drawings, 2008 

UTM or Lat/Long Location 

N51 o 14.345’, W92 o 09.248’ 

UTM 15 U 569048 5676753 

Road Name 

Springpole Trail 

MNR Region 

Northwest Region 

Forest Management Unit (FMU) 

Trout Lake Forest 

Bridge Length: 

30 feet 

MNR District (Area) 

Red Lake 

Site Specific Bridge Drawings (if applicable): 

Drawing 1 of 1, General Arrangement Drawing, Adamson Consulting, dated Oct 13/12 

Streambed to Soffit: 

7.0 feet 

Portable Bridge Identification Number: 

n/a 

Bridge Owner Information 

Bridge Owner Name 

Owner’s Contact Name 

Gold Canyon Resources Darryl Boyd 

Mailing Address 

Suite 810, 609 Granville Street 

P.O. Box 10356, Pacific Centre 

Vancouver, BC, V7Y 1G5 

Home Phone 

519-746-2624, Cell 519-616-2624 

Fax Number 

Email Address 

d.h.boyd@sympatico.ca 

This form was completed by the person responsible for the bridge, who is: 

Owner’s Representative Professional Engineer Competent Project Co-ordinator 

(for temporary bridges only) (for any bridges) (for bridges using standard designs) 

Name: Robert Bruce Adamson P.Eng. Registration No. (if applicable) : 235010 Phone No. 807-345-7073 

Company Name: Adamson Consulting Fax No. 

Mailing Address: 

126 Prospect Ave. 

Thunder Bay, ON, P7A 5L4 

Email address 

adamsonb@shaw.ca 

The undersigned confirms that the bridge structure referred above conforms to the requirements specified 

in the MNR document titled ‘Crown Land Bridge Management Guidelines”. 

Signature 

Date Signed 

October 13, 2012

BRIDGE SITE DATA FORM – EXISTING CONDITIONS 

Deaddog Creek, Springpole Camp Trail, Gold Canyon Resources 

prepared by Bruce Adamson, October 13, 2012 

A = Floodplain Width = 138 feet Measured Stream Velocity = 

B = Bankful Width = 14 feet Date velocity measured on: 

C = Channel Width = 14 feet Watershed: 

D(l) = Depth at 25% of Channel = 0.55 feet Drainage Area = 14.7 sq km 

D(c) = Depth at 50% of Channel = 0.55 feet Lake Area = 2.94 sq km 

D(r) = Depth at 75% of Channel = 0.55 feet Wetlands Area = none 

E = Depth of Bankful Flow = 1.5 feet Slope = 0.0031 m/m 

F = Depth of Floodplain = 5.55 feet Design Flow (Q 25 ) = 3.3 m 3 /sec (MNR 

PROPOSED BRIDGE DIMENSIONS: TYPE A TYPE B X TYPE C or SEE ATTACHED SKETCH X 

G = Bridge length = 30 feet Estimating Waterway Capacity 

H = Clear opening width = 24 feet Bridge opening area below 0.5 m freeboard = 3.4 sq m 

I = Freeboard (min. 0.5 m) = 1.6 feet 

Manning’s equation 

J = Flood rise = 5.0 feet Manning’s ‘n’ = . 

K = Fill height = 6.7 feet Channel Slope = m/m 

L = Left slope length = 6.0 feet (north side) Calculated velocity = m/sec 

M = Left slope rise = 2.2 feet 

Measured flow velocity = ___________ m/sec 

N = Right slope length = 6.0 feet (south side) X Assume 1 m / sec flow velocity 

O = Right slope rise = 2.2 feet Waterway capacity (Bridge opening area x velocity) 

P = Crib width = 8.0 feet = 3.4 m 3 /sec (must be > Q 25 ) + 0.5 m freeboard

Crib Round Summary Table - 30' Deaddog Creek Bridge, Springpole Road, Gold Canyon Resources 

Numbers per crib round, refer to drawing for round numbers. Cribs are 6.67' high 

Rnd # 8x8x16' 8x8x10' 8x8x8' Pins 18" Bolts 

1, bottom 3 4 8 

2 8 24 3 

3 3 3 24 

4 8 24 3 


6, blocking 1 2 6 32 3 

7, bearing 3 2 24 3 


9, blocking 1 5 28 3 

10, butt block 1 2 1 6 - 

Total / crib 14 12 39 210 23 

Total / bridge 28 24 78 420 46 

Notes: 

8"x8"x10' includes 5' crossers (field cut) 

8"x8"x8' includes 4' splices (field cut) 

RBA Oct 13/12

Materials - 30' Deaddog Creek Bridge, Springpole Road, Gold Canyon Resources 

Timber Item Deck Cribs Extra Total Bd Ft 

12" x 12" x 16', bearing timber 2 2 384 

8" x 8" x 16', crib stretcher, curb 4 28 2 34 2,901 

8" x 8" x 10', crib 24 24 1,280 

8" x 8" x 8', crib 78 2 80 3,413 

3" x 8" x 16', railing, curb blocking 8 1 9 288 

1" x 8" x 16', crib liner 34 2 36 384 

Total Timber 8,651 

All timbers to be SPF #2 grade or better, pressure treated with CCA to CSA 080 specification 

Hardware Size Length Number Note 

Bolt, bearing timber 3/4" 30" 10 galv 

Bolt, butt block to crib 3/4" 26" 10 galv 

Bolt, double crossers, curb to post, 1 extra 3/4" 18" 57 galv 

Bolt, railing to post 3/4" 14" 10 galv 

Lag bolts, for stringer guides 3/4" 8" 6 galv 

Timber washers, 3" round ogee 13/16" hole 184 galv 

Spikes, 3x8 blocking to curb 6" 16 galv 

Nails for crib liner 2.5" 5 lb galv 

Drift pins, 15 M rebar 5/8" 14" 430 10 extra 

Dywidag or threaded rods, w/2 nuts each 3/4" 25' 2 galv 

Plate washers for wingwall with 1" hole 8" x 10" 1" 4 galv 

Hazard marker Wa-33L, with bolts 1' x 3' 2 

Hazard marker Wa-33R, with bolts 1' x 3' 2 

Narrow bridge sign Wa-24, with bolts 30" sq 2 

Steel sign posts 10' 6 galv 

P2000 insulation for bridge end gap 1" thick 4'x8' 1 sheets 

Copper napthanate preservative 4 litre jugs 4 

Geotextile, non-woven, medium thickness 

2000 sq ft 

Other Material 

30-foot modular bridge meeting MNR 

standards, Lessard Welding or Rock 

RBA Oct 13/12

Project Description for Submission to Transport Canada Under the NWPA 

Birch River Bridge, Springpole Road, East of Red Lake, District of Kenora, ON 

Project History 

Gold Canyon Resources Inc. is a mining exploration company with an active drilling program on 

properties it holds near the west end of Springpole Lake. The drilling program is supported by a 

sixty person tent camp with cookhouse, sewage treatment plant, domestic water supply, core 

shacks, storage, dock, heli-pad and ancillary lay down areas. Access to the Springpole Camp is 

currently by helicopter, float plane and a seasonal ice road across Birch Lake to the north of the 

camp. 

It is projected that increased drilling activity and mine development will occur over the next few 

years and it is necessary to improve access to the Springpole Camp. An existing forest access 

road is located south of the camp (Wenasaga Road 82-6). It is proposed to build a forestry winter 

operational road from the existing road to the camp, a distance of about 40 km. At 18.2 km along 

this route is the Birch River, a large river crossing. It is proposed to build the Birch River Bridge to 

primary road standard in order to provide better protection of environment and to facilitate future 

upgrades to the road without impacting the river. For simplicity, the trail and future forest access 

road, will be referred to as Springpole Road. 

A proposed road to Birch River is approved in the current Forest Management Plan (2009-2019) 

prepared by Domtar for their Trout Lake Forest. The corridor location for this section was 

approved by the Ministry of Natural Resources (MNR), following Ontario’s forest management 

planning process, including public and First Nation consultations. Beyond Birch River, to 

Springpole Camp, the proposed trail follows the route of a largely pre-existing mineral exploration 

trail. 

The route crosses Crown land and mining claims held by Gold Canyon Resources. No other 

private properties are crossed. The road crosses Birch River near the outlet from Springpole Lake, 

at the east end of the lake. The location is N51 o 19.959’ W92 o 03.618’ (15U 565465 5687236). It 

is shown on the 1:50,000 scale topographic map Birch Lake (52 N/8). 

It is proposed to build a permanent bridge on the short-term trail, so it needs no further upgrading 

when the all-weather forest access road is constructed. 

It is proposed to cross Birch River with a clear span structure 120 feet long. A site visit was made 

on October 6, 2012, when flows were lower than average. From records at a downstream flow 

gauge station it was determined the flow at the time was 15 m 3 /sec, compared to the mean 

October flow of 20 m 3 /sec. During the visit a field survey was undertaken to provide data for bridge 

design. 

Adamson Consulting is an engineering consultant to Gold Canyon Resources Inc., assisting with 

design and approvals for water crossings along the route. 

Project Design 

An hydrology analysis was completed following the MNR method. Another analysis was done 

using the Single Station Frequency Analysis Method, as set out in the MTO Drainage Management 

Manual, 1997. Within the same watershed, downstream of the bridge site, is the Water Survey of 

Birch River Bridge Adamson Consulting Page 1 of 6 

Springpole Trail October 21, 2012

Canada flow gauge on the Cat River, below Wesleyan Lake (04GA002). Drainage area at the 

bridge site is 1366 km 2 and it is 5390 km 2 at the gauge. Forty-three years of record are available. 

The latter method resulted in a higher flood flow, so this is used for design. 

The proposed bridge is 36.58m (120’) long to clear span the channel. The bridge will be high 

enough to meet minimum vertical clearance requirements for floods and navigation. The proposed 

superstructure will be a modular truss bridge design. The bridge abutments will be treated timber 

cribs, similar to most bridges on forest access roads in Ontario. The design drawings for the 

project are: 

Drawing 1 of 2, General Arrangement Drawing, Adamson Consulting, Rev. 1, Oct 18/12 

Drawing 2 of 2, Bridge Abutment Construction Drawing, Adamson Consulting, Oct 15/12 

Construction Strategy 

At present, it is proposed to construct the Birch River Bridge in February or March of 2013. This is 

the open fisheries timing window when the risk to fish is lower. Access for construction will be 

along the new trail construction route. 

The bridge abutments will be located back from the water’s edge, therefore no permanent instream 

excavation or in-stream fill will be necessary. February and March are the months with the 

lowest flows and water levels during the year. 

Bridge construction will be carried out by a competent and experienced bridge contractor and Gold 

Canyon Resources will arrange to monitor construction and do a final inspection to confirm the 

bridge is built properly. Any significant problems or deviations from the drawings will be brought to 

the attention of the design engineer for advice. 

On the bedrock river banks rock excavation will be necessary to achieve satisfactory road grades 

and to found the crib abutments on level ground. The material removed will provide rock rip rap for 

erosion protection in bridge and culvert construction. 

Although the contractor has not been selected yet, in general terms the expected strategy is: 

1. Mobilize equipment and materials (incl. timber, steel superstructure, hardware, crib fill, ramp fill 

and rock rip rap materials) to the site by winter ice road over Springpole Lake from the camp to 

the outlet of Birch River from the lake. 

2. At present, the planned winter ice road would allow access to both sides of Birch River by trails 

from Springpole Lake. If all goes as planned, it shouldn’t be necessary to ford the river for 

construction. However, the fall-back plan in case of schedule delay or unseasonably warm 

weather, would be a one time ford (across and back) by the backhoe to the far shore, as 

permitted by DFO’s Operational Statement for Clear Span Bridges. Due to the steep 

approaches, the ford crossing may have to be at Site #1, approximately 200m upstream of the 

proposed bridge site. 

3. At each abutment location, the foundation area will be prepared by bedrock excavation and the 

crib abutment will be constructed to the bearing level. 



4. The approach ramp on the accessible west side will be constructed to bearing level. 

5. The steel superstructure will be installed by the cantilever launch method, from one side. 

6. The approach abutment and ramp will be completed to grade. 

7. The far side ramp will be constructed by end-dumping off the bridge and the far side crib 

abutment will be filled. 

8. The far side abutment will be completed to grade 

9. Rip rap erosion protection will be placed in front of the cribs and on the fill slopes. 

10. Final trimming and disposal of surplus materials will complete the project. The bridge will be 

inspected for compliance with design and approval conditions. 

Applicable Environmental Standards and Conditions 

The design and construction is governed by the following Federal and Provincial standards related 

to this type of bridge on a forest access road. 

DFO’s 1 Ontario Operational Statement for Clear Span Bridges, Version 3.0, 2007 

 

MNR’s 1 Forest Management Guide for Conserving Biodiversity at the Stand and Site 

Scales, 2010 

MNR’s Crown Land Bridge Management Guidelines, 2008 

MNR=s 1 Environmental Guidelines for Access Roads and Water Crossings, 1988.” 

. 

1 available in PDF format on-line from regulators’ websites 

These documents contain pages and pages of standards and recommended mitigation techniques 

applying to on-site operations involved in this project. They are not repeated here to simplify this 

report, although readers are encouraged to check them out. By using a competent and 

experienced bridge contractor familiar with applicable requirements and by doing compliance 

monitoring it is expected they will be followed. 

Public and Aboriginal Consultation 

Gold Canyon Resources has met with the Trout Lake Forest Local Citizen’s Committee (“LCC”) 

and engaged with the outfitters in the region. The proponent is committed to advancing the public 

consultation process and intends to hold a public consultation meeting, as required by Section 

140(b) of the Mining Act in the near-term. 

Gold Canyon Resources has undertaken consultation with aboriginal communities under the 

guidance and direction of the provincial government. They are engaging Lac Seul First Nation, Cat 

Lake First Nation and Slate Falls First Nation. 

References 



Crown Land Bridge Management Guidelines, MNR, 2008 

1 Ontario Operational Statement for Clear Span Bridges, DFO, 2007 

1 Environmental Guidelines for Access Roads and Water Crossings, MNR, 1988 

1 available in PDF format on-line from the regulators’ websites 

This report was prepared for Gold Canyon Resources Inc., on October 21, 2012 by, 

Bruce Adamson, P.Eng. 

Adamson Consulting 

Thunder Bay, ON 

(807) 345-7073 



Photo 1: Birch River crossing site, looking west. Red flags mark proposed centerline. 

Photo 2: View from abutment site on east bank, looking downstream (south). 



Photo 3 – Site #2 indicates proposed bridge location, Site #1 indicates ford location. 

Photo 4 – View of ford location at Site #1. 



APPENDIX 7 

7C: SEDIMENT CONTROL PLAN 

AND WATER CROSSING 

INSTALLATION PLAN

Springpole_GenericSedInstall_____________________________________________________10July2013 

Gold Canyon Resources Inc Springpole Project Access Road: 

Generic Sediment Control and Installation Plan 

Crossings # 2,3,4,5,6,8,9,10,11,12,13,14 

Date: 10 July 2013 

Prepared by: Steve Bros, R.P.F., Merin Forest Management 

1.0 Purpose 

This Generic Sediment Control and Installation Plan will be used for Crossings 

# 2,3,4,5,6,8,9,10,11,12,13,14 as identified on the Springpole Road ROW corridor map in the Bruce 

Adamson Water Crossing Report Springpole Road (October 21, 2012). 

Crossing 2 to 6 are located within the Trout Lake Forest FMP approved Wenasaga Road Corridor. 

These crossings will be constructed to the primary road standards outlined in the FMP and the 

Domtar Standard Operating Procedures (a copy is supplied as a supplementary document – Domtar 

Road Construction SOP) 

2.0 Applicable Guidelines for Project 

In addition to the Domtar Standard Operating Procedures, the following MNR Guideline Manuals and 

Department of Fisheries and Oceans (DFO) Operational Statements will be on site for reference by 

the Site Supervisor: 

• The Environmental Guidelines for Access Roads and Water Crossings (1995), 

• Engineering Northeast Region Culvert Sizing at Water Crossings (1998), 

• Crown Land Bridge Management Guidelines (2007), 

• CSP Culvert Installation at Water Crossings on Forest Access Roads (1996), 

• Erosion and Sediment Control at Water Crossings on Forest Access Roads Field Card (2000) 

• MNR Guidelines for Culverts Installed in the Winter (1996) 

• Instream Sediment Control Techniques Field Implementation Manual (1996) 

• DFO operational statements 

• Culvert Maintenance Ver 3.0 

• Ice Bridge and Snow Fills Ver 3.0 

• Clear Span Bridges Ver 3.0 

• Bridge Maintenance Ver 3.0 

• Timing Windows Ver 1.0 

3.0 Project Administration and Scheduling 

Personnel involved in this winter road construction and stream crossing installations will be instructed 

on the procedures in this plan prior to the start of the project. This instruction will be completed by the 

onsite project supervisor who will: 

1. Have MNR stream crossing training on sediment control and culvert installation. 

2. Have training on operational application of the MNR Stand and Site Guide. 

3. Be a certified forest operations compliance inspector. 

4. Be experienced in forest operations, winter road construction and stream crossings. 

The crossing installation will occur upon MNR approval and is tentatively scheduled for the period 1 

October 2013 to 31 March 2014. The crossings are all classified as cool water. 

______________________________________________________________1 of 11


4.0 Crossing Options 

The objective is to install culverts at all the crossings. Each crossing has been marked and stream 

locations have been staked during summer 2013 to facilitate location of the creek for winter culvert 

installation. To ensure all creeks can be crossed 3 crossing options are proposed, this strategy is 

being implemented to cover any unforeseen problems or issues that may be encountered. 

Option 1 – Stream Simulation culvert as identified in Figure 1. It is planned and anticipated that all 

crossings will be installed with culverts, however, if a temporary (1-2 weeks) crossing is required 

before a culvert can be installed to move machinery; then, 

Option 2 – A winter snow and ice bridge will be installed to allow for temporary passage of a creek. If 

a culvert cannot be installed after temporary passage of a creek for some unforeseen reason; then, 

Option 3 – A temporary MNR standard portable timber bridge using MNR Standard Abutment Design 

installed with a Q25 opening will be used. A formal MNR application will be made with hydrology and 

drawings as required. 

5.0 Crossing Installation and Sediment Control Plans 

5.1 Culvert 

5.1.1 Culvert Sizes 

The installation will be completed to Stream Simulation standards as per the Adamson report outlined 

in Figure 1. 

Figure 1. Stream Crossing Number and Associated Stream Simulation Culvert Size 

Crossing Q100 Culvert Dia (mm) Culvert Length (m) 

2 1200 10-20 

3 1400 10-20 

4 1200 10-20 

5 1400 10-20 

6 1400 10-20 

8 1200 10-20 

9 1400 10-20 

10 1200 10-20 

11 1000 10-20 

12 1000 10-20 

13 1000 10-20 

14 1200 10-20 

Source: Adamson, B. (21 Oct, 2012) Table 2. Water Crossing Hydrology Results, Springpole Trail, East of Red Lake of 

Water Crossings on the Proposed Springpole Trail, East of Red Lake 

5.1.2 Installation and Sediment Control Plan 

• The winter installation of these crossings will be based on the MNR Guidelines for Culverts 

Installed in the Winter (1996) a copy of which is found in Appendix A. 

• The listed steps correspond to Figures 2 and 3 illustrating the installation and sediment control 

plan. Prior to installation an onsite training course will be performed to describe: 

• The values to be protected. 

• How the control measures work 

______________________________________________________________2 of 11


• How to install and monitor the control measures 

Installation 

1. No digging, grubbing or ditching will occur within the flood plain or 30 m past the flood plain. 

2. No debris will be dropped in the stream any debris that inadvertently falls into the stream will be 

removed. 

3. Snow and ice will be removed from the work area. 

4. The culvert installation will be in the wet for all cool water streams. 

5. For those streams that are determined to be cool water (no in water work from September 15 

to June1) culvert installation will be in the dry by using sand bag coffer dam as outlined in the 

MNR NEST Field Guide - Instream Sediment Control Techniques Field Implementation Manual 

and illustrated in outlined in Figure 2. 

6. As required, silt fences constructed of staked geotextile will be placed along the road edges to 

keep material from entering the creek. The silt fences will be long enough to cover the work 

area i.e. excavator work area and stock pile area. The silt fences will be the standard width of a 

geotextile roll (1m). 

7. Measurements downstream of water depth will be verified and the excavator will ensure the 

depth of the culvert will be 40% below this level. 

8. The appropriate culvert for the crossing as outlined in Figure 1 will be installed 40% into the 

stream bed. 

9. The grade of the culvert will reflect the grade of the natural stream bed. 

10. If the stream bed is rocky the culvert will be placed on top of the rock/bedrock. 

11. Erosion resistant gravel will be used to pack around the culvert as shown in Figure 3. 

12. The excavator will back fill the gravel in 300mm layers and pack each layer before adding the 

next layer. 

Long Term Erosion control 

1. A layer of coarse erosion resistant crushed granular B gravel will be used to cover and crown 

the road. 

2. All slopes will be left at 2:1. 

3. Acid free rip rap of various sizes will be used to stabilize the culvert ends as shown in Figure 3 

Step 4 -5. Any exposed areas will be seeded with an approved seed mix and/or local organic 

material and vegetation. 

4. As required diversion ditches or berms will be used to direct water into sediment settling 

structures (slash, settling holes, natural vegetation) 

Reclamation and Rehabilitation 

The following steps will occur: 

1. The rip rap will be excavated and stockpiled on the road for use after the culvert removal. 

2. All material used to cover the culvert will be removed and transported from the crossing site and 

spread along the existing road in a 20 cm deep layer. 

3. The culvert will be removed and disposed of at a proper recycling centre. 

4. Measurements of water depth will be taken up/down stream from the crossing. An average 

water depth will be calculated. 

5. The stream bed at the crossing will be left at the average calculated depth. 

6. The slopes from the stream will be pulled back and sloped at 2:1 or greater to minimize water 

erosion. 

7. The rip rap will be used along the water edge to form a protective barrier 25 long by 1m wide 

and .20-.30 m deep. 

______________________________________________________________3 of 11


8. The exposed slopes will be seeded with non invasive species and/or local black muck with 

vegetation. 

Figure 2. Cofferdam Installation Specifications and procedure 

Source: Trow Consulting Engineers Ltd for MNR Northeast Region Instream Sediment Control Techniques Filed 

Implementation Manual NEST Field Guide January 1996 

______________________________________________________________4 of 11


Figure 3. Culvert Installation Specifications and Procedure 

______________________________________________________________5 of 11


(Source: MNR - CSP Culvert Installation Field Card) 

______________________________________________________________6 of 11


5.2 Winter Snow and Ice Bridge 

• The winter stream crossing will be used when creeks are completely frozen and movement of 

machinery is required before a culvert can be installed. 

• The DFO Operational Statement for Ice Bridges and Snow Fills will be followed. 

• Winter snow and ice bridge will only be used on streams less then 1m wide. 

5.2.1 Installation and Sediment Control Plan 

Installation 


2. No debris will be dropped in the stream any debris that inadvertently falls into the stream will 

be removed. 

3. Feller buncher will install brush mat on the approaches to the stream so as to avoid rutting or 

site disturbance in the flood plain. 

4. Snow will be excavated and placed on top of the creek, packed and allowed to freeze. 

5. The packed snow will be flooded with water from a tanker obtained from one of the larger 

flowing streams within the corridor and allowed to freeze. 

6. A layer of geotextile will be placed on top of the frozen snow/ice pack and snow will be placed 

on top of this to create the travel surface (illustrated in Figure 4) 

Figure 4. Snow and Ice Crossing Diagram 

Erosion Control 

1. No grubbing or ditching within 30m of the creek will occur 

2. Before the spring freshet the geotextile will be removed and snow and ice broken to ensure 

water flow is not impeded. 

5.3 Portable Bridge Installed under Frozen Conditions 

• A MNR standard portable timber bridge will be used only as a last resort if unforeseen 

problems prevent installation of a culvert 

• Installation of portable bridges will adhere to the standards in the Crown Bridge Management 

Guidelines (2008). 

• Bridge size opening will be installed to a Q25. 

• The MNR Standard Portable Timber Bridge Design and MNR Standard Abutment Design will 

be used as the standard for the bridge. 

5.3.1 Installation and Sediment Control Plan Installation 


2. No debris will be dropped in the stream any debris that inadvertently falls into the stream will 

be removed. 

3. Feller buncher will install brush mat on the approaches to the stream so as not to create 

rutting or site disturbance in the flood plain. 

______________________________________________________________7 of 11


4. Approaches to the bridge will be straight. 

5. Engineered sill timbers as per the MNR standard abutment design will be placed on the banks 

at the maximum design distance allowed as per the design drawing. 

6. The bridge will be placed on the sill timbers. 

7. A layer of geotextile will be placed on the bridge ends and rolled out for 5 m along the road 

bed 

8. Corduroy will be placed on the bridge approaches to create a ramp to the bridge 

9. The corduroy ramp will be covered with snow/ice mixture and frozen to create the travel 

surface 

10. Bridge warning signs and corner markers will be installed 

Erosion Control 

1. Before the spring freshet the approaches to the bridge will be excavated and removed from 

the flood plain, brush mat material will be spread along the road at least 30 m from the stream 

2. The bridge will be removed. 

3. Any exposed slopes will be stabilized to 2H:1V and slash will be used for erosion control on 

exposed mineral soil 

4. During the summer work season a permanent culvert will be installed as described in 4.1.2. 

6.0 Contingency Plan 

Any changes to this plan must be approved by the MNR. MNR approval will be required for all major 

deviations from this plan. 

7.0 Inspection and Maintenance 

GCU will adhere to the standards for compliance for forestry operation in Ontario through the forest 

operation inspection program (FOIP). GCU will: 

a. Provide email notification to Red Lake MNR 7 days prior to Start up of ROW harvest 

and road construction 

b. Upon completion of the harvest and each stream crossing a forest operations 

inspection will be completed by a certified inspector and filed through FOIP. 

______________________________________________________________8 of 11


Appendix A. MNR Guidelines for Culverts Installed in the Winter 

______________________________________________________________9 of 11


MNR Guidelines for Culverts Installed in the Winter 

Winter culvert installations should be avoided if at all possible due to the difficulty in 

obtaining adequate backfill compaction. For this reason, winter installations are not 

recommended by the culvert supplier Armtec. Their studies have shown that "dry" 

backfill placed in winter will attain compaction in the 70 to 85% range. The normal 

minimum expected is 90%. Failure to attain backfill compaction can mean inadequate 

soil arch development resulting in pipe collapse or washout. This would prove costly to 

the builder and will harm the environment. 

The increased risk to fish habitat downstream of a winter installed culvert requires MNR 

to impose special guidelines. Adherence to these guidelines is no assurance the pipe 

installation will be successful. The onus is on the builder to ensure there is no harmful 

alteration, disruption or destruction to fish habitat at the site or downstream as a result 

of the work. 

These guidelines apply to water crossing culvert installations constructed between mid- 

November and the end of April, referred to as "winter". Approval conditions and 

environmental protection measures used for all culvert crossings also apply to winter 

installations. It is expected that proper culvert installation techniques, as recommended 

in Installation Manual available from MNR, will be followed. 

1. Maximum pipe diameter for winter installation is 1800 mm. Any proposal to install a 

larger size will require approval of the MNR Engineer. Approval will depend on 

satisfactory experience in installing large culverts and having a source of "dry" wellgraded 

gravel material for backfill. 

2. The site must be visited by the applicant before snow covers the ground to assess site 

conditions and foundations. The pipe alignment and grade must be laid out before snow 

cover arrives. 

3. The backfill material must be a "dry" well graded gravel having a range of particle 

sizes from gravel to sand. Silt and clay content must be less than 10 percent. A low 

moisture content is required to minimize the formation of frozen lumps and to improve 

the chances of satisfactory placement. 

4. Backfill material must be hauled in trucks having heated boxes. Backfill material must 

not contain ice or frozen lumps. Backfill material is to be placed in thin layers, brought 

up evenly on both sides and compacted, similar to non-winter installations. 

5. The minimum thickness of pipes installed in the winter is 2.8 mm. 

______________________________________________________________10 of 11


6. Fill slopes are to be no steeper than 2H:1V and good quality rip rap material is to be 

placed around the pipe ends to protect the fill from erosion. 

7. In the spring, when the frost is out of the ground, the pipe is to be inspected by a 

competent person familiar with MNR requirements. Significant settlement of the road 

fill beside the pipe or distortion of the pipe out of round by more than 10 percent is 

cause for concern. If either condition is observed, the backfill is to be removed to water 

level for a distance of 3 metres on each side of the pipe and replaced in the normal 

manner, with compaction. Any sources of erosion that will cause sediment to enter the 

creek are to be treated to meet requirements of the work permit. 

8. The coupler can often be a weak link in culvert installations. If possible, a one piece 

culvert should be used as opposed to one that requires coupling (i.e. 1 x 18m vs. 3 x 6 

m). 

9. Snow cover can easily make one forgetful of the importance of constructing measures 

to control runoff water to prevent sediment. Attention must be paid to good diversion 

berms or off shoot ditches into the standing timber. 

10. Any potential settling of the culvert will usually be concentrated under the load of 

the backfill. Consequently, the ends of the culvert could have a tendency to "float up". 

The culvert ends should be weighted with cobble to promote even settling if any settling 

should occur. This material can be pulled back after spring thaw. 

11. A few loads of good backfill material placed handy to site will rarely go to waste. A 

stockpile will reduce the need for full mobilization of a construction crew if a deficiency 

is detected. If the stockpile is not needed for the crossing, it can be utilized to fix a soft 

spot on the road. 

RBA1996 02 20 

Source: MNR Water Crossing Work Shop Material North East Region 

______________________________________________________________11 of 11

APPENDIX 8 

SUMMARY OF COMMENTS ARISING 

FROM COMMUNITY 

CONSULTATION SESSIONS WITH 

PROTOCOL NATIONS

Comments Received at Open Houses conducted on May 27, 28 and June 11 

Concern / Question Mitigation / Response Raised by 

concern about decommissioning of the 

road if GCU does not go ahead. What if 

another party wants the road to 

remain? 

Only the north portion of the road, beyond the FMP-approved section would be 

decommissioned by GCU, and even then, if someone requested that the road remain, 

they could complete their own EA to take over responsibility for any portions they 

wanted to remain. 

SFFN community member 

asked if GCU would connect to a road 

coming from Vermillion Lake (Polar 

Road) 

concern with the road options and 

alternatives, interest to provide access 

between Lac Seul, Slate Falls and Cat 

Lake, as this would assist with the Lac 

Seul Forestry company with their access 

road maintenance. 

GCU could look at this in the future, but another EA would need to be completed. At 

this time, GCU is proposing a winter road only to connect to the Wenasaga Road and 

not an all-weather road. 

a SFFN and 2 LSFN community members 

asked if the Springpole Project is 

developed into a mine, will another EA 

be conducted. 

GCU will have to conduct a separate EA for the mine development, and there will be a 

long involved consultation process related to that EA. 


asked if FN communities will be building 

the road 

GCU responded that an Request for Expression of Interest had been sent to all 

Aboriginal partner companies that were identified by CLFN, SFFN, LSFN, WFN and 

MNO, as well as a contractor from Ear Falls. When GCU gets to a point where we are 

confident we can proceed with the project, we will get back to those companies and 

proceed with the contract to one or more of the companies. The contract(s) will be 

awarded based on a combination of the best plan for community involvement, price, 

experience on similar jobs and safety & environmental protection record. 

Several community members from SFFN, 

CLFN and LSFN. 

asked if there were any species at risk at 

the road corridor, specifically whip-poorwill 

GCU indicated that there are no known (eastern) whip-poor-will in the project area 

based on DST's studies to date. DST Consulting (qualified independent biologist) has 

also considered wolverine and caribou and the proposed corridor has been designed 

and selected to mitigate effects to these species at risk that are known to be present in 

the region. 

CLFN community member 

asked about other species in the area, 

including wolverine, caribou and owls. 

CLFN community members have seen 

them in the road corridor area in the 

past. 

GCU indicated that no wolverine have been found during the course of DST's field work 

and although wolverine are known to be present in the project area it would not be 

practical to collect meaningful baseline data for this species against which future 

potential impacts could be measured. GCU is sensitive to all species at risk. The 

eastern corridor was selected because it was deemed to have less impact to SAR's. 

Caribou reside in the area around the northern portion of the road, so GCU has been 

working with the MNR to plan a process that will ensure a net overall benefit to 

caribou in the area 


asked about endangered plant species in 

the area. 

asked if GCU would conduct any 

spraying during road construction to 

clear the road corridor 

DST has not found any rare or endangered or at risk plant species in the project area. 

GCU will not be conducting any spraying during road construction, or any other phase 

or the project. Timber harvesting will be conducted utilizing mechanical methods only 


SFFN and CLFN community members 

asked if FN communities will be 

contacted if there is ever a spill in the 

area. 

GCU staff and contractors are trained in fuel handling and spill response according to 

GCU's Emergency Spill Response Plan, which includes notification to GCU, all relevant 

government agencies and First Nation Band Offices in the event of a spill. 


comment that the road planning should 

be a 4 party process: MNR, Domtar, 

GCU and First Nations 

GCU has consulted with MNR throughout the process. The proposed access corridor 

will serve the needs of Domtar's future planned forestry roads and GCU understands it 

also has synergies with an all-weather road to CLFN. 


comment that there should be an 

exploration agreement in place before 

any work is conducted in the area. 

GCU has been supporting the negotiation process and looks forward to an exploration 

agreement with the FN's; MNDM added that the reason for the open house session 

was to solicit feedback on the proposed plans before the work is conducted. 


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concern about the placement of a gate 

on the road and closing access to First 

Nations is impacting their Treaty Rights, 

noting that the gate would not restrict 

their access to the area, just to the use 

of the road. 

GCU is not permitted to allow selective access along the road corridor; although the 

gate will restrict use of the road corridor, First Nations use of the area will not be 

restricted, as they will still be able to access the area using the same means as they 

used prior to construction of the access corridor. 

LSFN councillor 

concern about the quality of the road 

and water crossings. In his experience 

with private companies, water crossings 

farther from the main road tend to 

decrease in quality and MNR needs to 

monitor them all 

All water crossings will be constructed to primary forestry road standards, according to 

MNR and DFO guidance documents, Domtar's standard operating procedures for the 

Trout Lake Forest, and using best practices (such as having competent contractors and 

supervisors and RFP auditors) and as described in the Final Environmental Screening 

Report (ESR) published in February 2013. The road will be monitored according to 

forestry industry standards as described in the Final ESR. 

LSFN councillor 

comment that a road in proposed area 

would be good, he would like a road 

there. 

GCU advised that the access to the road would be restricted to GCU workers only at 

the gate locations (first at Dead Dog Lake and then before the Birch River) at least until 

the forestry company takes over responsibility for the road. This did not change the 

opinion. 

CLFN trapline holder 

The access corridor is in a good location 

to be extended to the community of Cat 

Lake. They are very interested in having 

a First Nation based/partner company 

complete the access corridor 

construction. This will bring jobs and 

contracts to the community. 









The Springpole Project has provided jobs 

and has been good for the community. 

No concerns with the proposed project. 

Interested in job opportunities with the 

Springpole Gold project. 

no concerns with the project; hopes it 

will provide employment for the 

community 

wants to see Cat Lake people employed 

and to see this road provide all-weather 

access for Cat Lake 

no concerns with the road proposal and 

has not heard any concerns from others 


Several community members from SFFN, 

CLFN and LSFN. 




many questions regarding training and 

employment opportunities for the road 

project and the exploration/future 

mining project 








GCU will be identifying work force requirements for the potential mine at Springpole 

and will communicate those requirements to the FN EDO's, along with the training 

requirements, in time to allow FN workers to receive appropriate training before the 

mine begins operation. GCU will also work with the EDO's to identify funding 

opportunities to cover training costs. 

Many participants from SFFN, CLFN, and 

LSFN 

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Other comments, unrelated to the road project 

concern for mining and draining the 

lake, worried about the quality of water 

which will drain through SFFN when 

mining starts; 

Comment that Springpole is an 

important lake. It is a source of clean 

drinking water, it is a naturally springfed 

lake, and is the deepest lake in the 

area. 

Mining is not being proposed at this time, this EA is for a winter road only to facilitate 

continued exploration and resource definition work. Although out of scope for this EA: 

GCU is committed to meet or exceed all MNR, MOE and DFO regulations and 

operational guidelines with respect to water quality; follow best practices for all work 

conducted on the property, and continue to conduct regular water quality testing to 

avoid negative impacts to Springpole and other lakes in the watershed. 

For the mining operation GCU will obtain an Environmental Compliance Approval 

pursuant to Section 20.2 of Part II.1 of the Environmental Protection Act. This approval 

imposes stringent effluent criteria that are protective of the receiving waterbody in 

accordance with provincial policy. In plain language, the waterbody needs to remain 

“fishable, swimmable and drinkable” and this approval often requires very stringent 

effluent criteria on discharges. 

Several SFFN community members, one 


concern that when GCU leases the land 

for mining activities there will be no 

benefit to the trapline holder for the 

land that is lost from his trapline. 

Although out of scope for this EA: GCU will work with the trapper to mitigate any 

impacts to his trapline activities to the best of their ability, however, GCU recognizes 

that the trapline holder will lose use of the part of his trapline area covered by the 

mining actifities for the duration of the construction, operation and reclaimation 

phases of the mine. At the end of the mine life, the lands used for mining will be 

reclaimed and restored to their natural state. GCU will work with the trapper to 

mitigate as many impacts to his trapping activities as possible, and provide 

accommodation for any impacts that cannot be mitigated. 


2 tradititional harvesting periods were 

identified: 

1 week in August for trout fishing in 

Springpole Lake and 

1 week in late September for moose 

hunting in the Birch/Springpole general 

area. 

Although out of scope for this EA: GCU is open to discussion about modifying or 

suspending activities at the project site during these Traditional Harvesting periods 

and/or allowiing workers to schedule time off to participate in these activities, thereby 

allowing Traditional Harvesting to be conducted on schedule. 


commented that a worker from CLFN 

was advised that he could not bring a 

firearm to the work site to be used for 

hunting while working for Gold Canyon 

Although out of scope for this EA: GCU recognizes FN rights to harvest in their 

Traditional Lands, but while in the employ of GCU, no workers will be allowed to 

conduct hunting activities in work areas as this is a safety issue. 


comment that the portage between 

Springpole Lake and Birch Lake are very 

important to the people of CLFN to 

access Birch Lake for harvesting 

Althought out of scope for this EA: GCU respects the rights of FN people to travel 

within their traditional lands and will not impede access through the portage between 

the 2 lakes. GCU would ask that travellers proceed slowly through GCU work areas, 

leaving a wide berth between their boats and the drill rigs on the lake, and that they 

report to the GCU camp office when they access GCU's dock at the camp site. 


commented that she would like to see a 

working group to comment on the Mine 

EA with other FN's to be part of the 

decision making 

Althought out of scope for this EA: GCU has suggested organizing a working group 

comprised of Aboriginal and stakeholder representatives to provide direct feedback on 

the mine EA, and potential future mine operations; similar organization to forestry 

Committees that are organized for Sustainable Forest Licenses (i.e. the Local Citizen's 

Committee for the Trout Lake Forest) 


concerns about increased traffic in the 

area, if there is a mine, which will have 

an impact on the wildlife in the area 

comment that sturgeon were previously 

present along Springpole Arm and in 

Gull Lake 

Out of scope for this EA: Under the current proposal, GCU is proposing only a winter 

access corridor which would see 3-4 trips per week during the freeze-up period, and no 

more than one trip per week outside the freeze-up period. Road usage restrictions 

through the use of a monitored gate and low speed limits will minimize the effects to 

local wildlife. The road use strategy for an all-weather mine access road would 

addressed if/when GCU proposes to upgrade the road to an all-weather road for mine 

site development. 

Although out of scope for this EA: information was relayed to DST to be incorporated in 

their fisheries studies 



3 of 4



comment that CLFN people have trails 

that come down the northern section of 

the road (west of Durkin Lake) 

comment that there are more moose in 

the RED84 burn area than before the 

fire 

request for a Springpole site visit for the 

youth of the community 

requested GCU provide core samples for 

the school to use in their educational 

program. 

Although out of scope for this EA: This information has been noted. GCU will attempt 

to avoid impeding access to CLFN residents using these trails to access their traditional 

lands. 

Although out of scope for this EA: This information has been noted, as it may indicate 

increased hunting pressures in the Red84 fire area. 

Although out of scope for this EA: GCU will attempt to organize such site visit in late 

summer, early fall. Also GCU could facilitate delivery of PDAC's Mining Matters 

educational program in the community, if there is interest from the school 

Although out of scope for this EA: GCU is in the process of collecting appropriate core 

samples and photos of drilling operations to put together an educational package to be 

delivered to CLFN school before September 2013 




CLFN teacher 

4 of 4

APPENDIX 9 

9A: SUBMISSION FROM TROUT 

FOREST TOURISM OPERATORS ON 

FINAL ESR DATED FEBRUARY 2013

Gold Canyon Resources Inc: Final 

Environmental Study Report Review 

Trout Forest Tourist Outfitters 

March 30, 2013 

This report is the property of Meaghan Labine, Harald Lohn, Vic Davies and 

Peter Kay, and any use of contents requires approval from all parties. 

ABSTRACT 

This report outlines the major concerns and deficiencies identified with Gold 

Canyon Resources Final Environmental Study Report and corresponding 

Baseline Technical Reports, as identified by Trout Forest Tourist Outfitters.

Gold Canyon Resources Inc: Final Environmental Study Report Review 

March 30, 2013 

Contact Information 

Meaghan Labine BSc, MSc, PhD Candidate 


info@birchlakelodge.com 

Harald Lohn BSc, MPA, MSW 

KaBeelo Lodge 

kabeelo@integra.net 

Vic Davies 

Northern Wilderness Outfitters 

fishcanada@nwonet.net 

Peter Kay 

KayAir Service & Outposts 

karenk@nwconx.et 

Please note: that the authors do not intend to speak on behalf of affected First Nation 

communities; Cat Lake First Nation, Slate Falls First Nation, Lac Seul First Nation and 

Wabauskang First Nation. We respect the individual concerns and rights of local First 

Nation communities, and only seek to support and help ensure that their traditional land, 

Aboriginal and Treaty rights are respected and upheld. 

2



March 30, 2013 

1 Overview .......................................................................................................................................... 4 

1.1 Report Objectives .............................................................................................................................. 5 

1.2 Stakeholders and First Nation Communities .................................................................................... 5 

2 Springpole Eastern Corridor Conflicts ................................................................................... 7 

2.1 Project Timeline ................................................................................................................................ 7 

2.2 Major Concerns Identified by Stakeholders...................................................................................... 7 

3 Federal and Provincial Policies ................................................................................................ 9 

3.1 Ontario Lakes and Rivers Improvement Act ..................................................................................... 9 

3.2 Ontario Water Resources Act ......................................................................................................... 10 

3.3 Ontario Heritage Act ....................................................................................................................... 11 

4 Class Environmental Assessment & Unresolved Environmental Issues .................. 13 

4.1 Good Neighbour Policy ................................................................................................................... 14 

5 ESR and Technical Report Deficiencies ............................................................................... 16 

5.1 Project Rationale ............................................................................................................................. 16 

5.2 Study Areas and Corridor Dimensions ............................................................................................ 17 

5.2.1 Study Area Dimensions ........................................................................................................... 18 

5.2.2 Eastern Corridor Dimensions ................................................................................................... 19 

5.3 Terrestrial Baseline Report Deficiencies ......................................................................................... 19 

5.3.1 Large Mammal Survey Deficiencies ........................................................................................ 20 

5.3.2 Small Mammal Trapping Deficiencies ..................................................................................... 24 

5.3.3 Bird Survey Deficiencies........................................................................................................... 25 

5.3.4 Vegetative Survey Deficiencies ................................................................................................ 28 

5.4 Aquatics Baseline Report Deficiencies ............................................................................................ 31 

5.5 Hydrology Baseline Report Deficiencies ......................................................................................... 34 

5.6 Habitat Fragmentation .................................................................................................................... 35 

5.7 Environmental Protection and Mitigation Plans ............................................................................. 35 

5.8 Cumulative Impacts Assessment and Residual Effects ................................................................... 36 

5.9 Future Corridor Upgrades ............................................................................................................... 37 

5.10 GCU and Domtar Synergies ............................................................................................................. 37 

5.11 Corridor Rehabilitation ................................................................................................................... 38 

5.12 GCU Preliminary Economic Assessment and Stock Volatility ......................................................... 40 

6 Summary of Recommendations ............................................................................................. 42 

3


March 30, 2013 

1 Overview 

Beginning in 2012, Gold Canyon Resources (GCU) put forward a proposal to develop a 

seasonal access road to their primary drilling exploration site at Springpole Lake. The road 

will extend roughly 43 Km northeast off the Wenasaga road from Ear Falls ON. After 

reviewing road alternatives, GCU decided to pursue a road through the eastern corridor, 

which requires clearing of roughly 645 km 2 of forested area. 

In 2011 GCU contracted DST Consulting Engineers to conduct general environmental 

baseline studies within the Springpole area. The general environmental baseline studies 

were used to develop future Environmental Study Reports (ESR) for various projects; 

eastern corridor development and increased mining exploration. 

In July 2012 GCU released their Springpole Exploration & Access Corridor Base Case 

Project Description Report, which was sent out to Stakeholders (tourist outfitters), First 

Nation communities and interested parties. In October 2012 GCU released the Springpole 

Gold Access Corridor Draft Environmental Study Report (ESR) to solicit feedback from 

Stakeholders, First Nation communities and interested parties. Numerous tourist outfitters 

raised objections to the project for reasons ranging from economic to environmental. 

In November 2012, four tourist outfitters; Kabeelo Lodge, Birch Lake Lodge, Northern 

Wilderness Outfitters and KayAir Service & Outposts (Trout Forest Tourist Outfitters), 

collaborated to seek legal counsel regarding unresolved socio-economic and environmental 

impacts resulting from eastern corridor development and operations. GCU did not provide 

adequate environmental mitigation measures, nor any feasible options to tourist outfitters 

for compensation due to economic loss incurred through loss of remote tourism value. 

On March 2, 2013 GCU submitted their Springpole Gold Access Corridor Project Final ESR 

under a Class C Environmental Assessment (EA), to the Ontario Ministry of Natural 

Resources (OMNR) for approval. Stakeholders, First Nation communities and interested 

parties received notification by email of the Final ESR from GCU, accompanied with an 

electronic copy of the Final ESR (no technical reports were submitted): the OMNR did not 

contact Stakeholders, First Nation communities or interested parties. 

This report is a review of the GCU Final ESR and Baseline Environmental Technical Reports 

(Technical Reports) submitted on March 2, 2013 to OMNR for approval by GCU, and 

highlights deficiencies encountered with the ESR, Technical Reports and Preliminary 

Economic Assessment, as reviewed by Trout Forest Tourist Outfitters. 

Stakeholders have been very clear to the OMNR and GCU, that continued exploration 

at Springpole does not require a winter road, and the rationale and baseline 

environmental studies used to justify the project are without merit. 

4


March 30, 2013 

1.1 Report Objectives 

1) To highlight the fact that GCU did not conduct the required baseline environmental 

studies from which the eastern corridor ESR was drafted, in order to gain OMNR 

approval for the project; 

2) That the project will have far reaching environmental impacts, and a more thorough 

environmental and socio-economic analysis is required prior to project approval. 

3) To request a Part II Order to elevate the Environmental Assessment requirements 

for this project from a Class C to a Class D. 

4) Require that GCU provide a Reclamation Bond with the OMNR to ensure that money 

is available for land rehabilitation. 

1.2 Stakeholders and First Nation Communities 

The Trout Forest area supports a variety of wilderness tourism operations, which promote 

northwestern Ontario and strive to maintain sustainable and environmentally conscious 

businesses. 

First Nation communities affected by Springpole exploration activities are Cat Lake First 

Nation, Slate Falls First Nation, Lac Seul First Nation and Wabauskang First Nation. Failure 

of GCU and the OMNR to recognize the traditional and Treaty lands impacted by GCU 

related Springpole activities, infringes upon Aboriginal and Treaty rights: Stakeholders 

support the interests and rights of local First Nation communities. 

Local tourist operators have a long established relationship with local First Nation 

communities, providing jobs and community support. Trout Forest tourism forms a strong 

component of local heritage and culture, which is evident in the Ear Falls and Red Lake 

communities, that work with and support local tourism. 

GCU conducted two “consultation” rounds with Stakeholders, First Nation communities, 

organizations and the public. Issues were raised about how GCU engaged with affected 

First Nation and non-First Nation parties, as there was little time between initial 

“consultation” and completion of the Draft ESR by GCU. 

5


March 30, 2013 

Table 1. List of Stakeholders, First Nation communities, organizations and interested 

parties, that GCU contacted throughout the spring and summer of 2012. 

Round One Consultation Round Two Consultation 

Tourist Outfitters: 

Pickeral Arm Camps 

KaBeelo Lodge 





True North Outposts and Camps 

Green Airways 

Bait fishermen: 

Best Baits 

Whitewing Floating Lodge 

D & E Minnows 

Bear Management Licenses: 

Green Airways 


Private Land Owners: 

Ruth Johnson 

Green Airways 




Douglas Bay Camp McKenzie John 

Ear Falls Contracting Ltd. Robinson Richard 

Ear Falls Hunters & Anglers Westcott Lloyd 

Ear Falls Trappers Council Lamond Lori 

Federation of Naturalists Estabrooks Gloria 

Hydro One Bowen John 

Ministry of Citizen, Culture, Tourism & Recreation Boulton 

James 

Ministry of Culture and Recreation Collins Brian 

Ministry of Labour Bartlett Daley 

Ministry of Northern Development & Mines Lichblau 

Andreas 

Ministry of the Environment Hoffmeister Matt 

Municipality of Red Lake Vinet Reeve Phil 

Native Trapper's Council Imbeault Ed 


North Lake Lodge Woolison Jerrold 

Northwest Metis Nation of Ontario Council Alvina Cimon 

President 

Northwestern Ontario Prospectors Assoc. Trelinski relinski 

Tomom 


Ontario Baitfish Association Bernier Ken 

Ontario Federation of Anglers & Hunters Pineo Robert 


Red Lake Trapper's Council Miron Benoit 

Township of Ear Falls Kahoot Mayor Kevin 


Windigo Tribal Council (represent Cat Lake and Slate Falls) 

Bimose Tribal Council (represent Wabauskang) 

Independent First Nation Alliance (represent Lac Seul) 

Aboriginal and Northern Development Canada (formerly 

INAC) 

Wildlands League Hesselink Trevor 

Greenpeace Brooks Richard 

Forest Ethics Grant Catherine 

Earthroots Armstrong Carly 

Ontario Natura Bell Anne 

6


March 30, 2013 

2 Springpole Eastern Corridor Conflicts 

2.1 Project Timeline 

Based on information extracted from various sections of the GCU ESR, Technical Reports 

and Stakeholder notes, below is the timeline during which submitted GCU road access 

reports and documents for review from 2012 – 2013. 

1. Springpole exploration and access corridor project: base case project description 

report, july 2012 

2. Springpole exploration and access corridor project: draft environmental study 

report (esr), october 2012 

3. GCU 2011 Baseline Study April 2012 

4. GCU 2011 Fisheries Baseline Study July 2012 

5. GCU 2011 Meteorology, Air Quality and Noise Baseline Study March 2012 

6. GCU 2011 Aquatic Baseline Study March 2012 

7. GCU 2011 Terrestrial Baseline Study April 2012 

8. GCU Preliminary Economic Assessment (PEA) March 26, 2013 

GCU began presenting information to Stakeholders, First Nation communities and 

interested parties during the spring of 2012. GCU presented on the economic benefit the 

project would provide for the community, and that there would be limited environmental 

impacts. At the time GCU began presenting to Stakeholders, First Nation communities 

and interested parties, the Draft ESR, Preliminary Economic Assessment and 

Baseline Environmental Technical Reports were not complete. 

GCU also failed to engage with First Nation communities prior to initiating desktop and 

field study work required for the Baseline Environmental Technical Reports. The Crown 

should have first notified and consulted with First Nation communities prior to GCU 

conducting any environmental work in the Springpole area. Failure to consult with First 

Nation communities infringes on traditional land use, Aboriginal and Treaty rights. 

What is evident from the timeline presented is that GCU wanted to expedite approval for 

the proposed eastern corridor and in their haste faile to 1) complete the required 

environmental and economic assessments prior to preparing an ESR and 2) properly 

engage with Stakeholders and First Nation communities potentially impacted by the 

project. 

2.2 Major Concerns Identified by Stakeholders 

After receiving the information from GCU on July 2012, regarding their intention to build 

an access road to the Springpole exploration property, concerned tourist outfitters in the 

area submitted letters of concern, objecting to the corridor development. 

7


March 30, 2013 

Issues identified by Stakeholders and Tourist Outfitters; 

Eastern corridor will have negative impacts on local tourism due to loss of remote 

value of the area; 

Creating new access to remote lakes; 

Increased noise and disturbance from road use and exploration activities; 

Destruction of viewscape at Birch River crossing; 

Establishment of a good neighbour policy; 

Damage to the environment, wildlife and water quality; 

Width of eastern corridor; 

Increased break-ins on property due to increased access to lakes; 

Habitat fragmentation and impacts to woodland caribou. 

Ultimately, Stakeholders are concerned that the eastern corridor project will 1) irreversibly 

jeopardize Trout Forest remoteness, which will permanently devalue Trout Forest tourism 

and 2) irreversibly destroy valued environmental landscape, wildlife habitat; woodland 

caribou and water quality. 

Issues brought forward by Stakeholders to GCU and OMNR received little attention, or no 

response at all. Comments were listed within the ESR (Table 3-2), however there was little 

follow-up on the part of GCU. 

Stakeholders have been very clear to the OMNR and GCU that continued exploration 

at Springpole does not require a winter road, and the rationale used to justify the 

project is without merit. 

Recommendation: GCU should not consider any issue identified by Stakeholders, First 

Nation communities, etc, as resolved until GCU receives confirmation in writing from the 

affected party that the issue is considered RESOLVED. 

8


March 30, 2013 

3 Federal and Provincial Policies 

Adherence to federal and provincial policies is required to ensure maximal protection and 

mitigation of potential socio-economic and environmental impacts or infringement of 

Aboriginal and Treaty rights. 

Throughout the ERS, continual mention is made by GCU of their being in the process of 

reviewing federal and provincial regulations specific for the project. This is of concern, 

given that a proponent applying for licensing should have reviewed and adhered to all 

federal and provincial regulations prior to the time of submission. 

GCU references meetings with Department of Fisheries and Oceans and ensuring that GCU 

is applying all the necessary measures required to mitigate against negative impact to fish 

habitat. However there is no discussion pertaining to what those mitigation measures are, 

nor that there will be consultation with affected tourist outfitters and First Nation 

communities (ESR, page 37). 

List of applicable acts referenced by GCU (GCU ESR, page 36): 

Navigable Waters Protection Act 

Federal Species At Risk Act – mammals and fish only 

Provincial Endangered Species Act – mammals and fish only 

Crown Forest Sustainability Act 

Public Lands Act 

Ontario Lakes and Rivers Improvement Act 

3.1 Ontario Lakes and Rivers Improvement Act 

The Lakes and Rivers Improvement Act has been referenced in the ESR, however there has 

been an oversite with its interpretation. Under part II of the Act: Public Rights in Lakes and 

Rivers, it stipulates that persons (proponents) shall not contaminate any water body. 

Lakes and Rivers Improvement Act, 1998, c. 18, Sched. I, s. 36. 

“Throwing matter into lake or river in conflict with purposes of Act 

36. (1) No person shall throw, deposit, discharge or permit the throwing, depositing or 

discharging of any substance or matter in a lake or river, whether or not the lake or river is 

covered by ice, or on the shores or banks of a lake or river under circumstances that conflict 

with the purposes of this Act. 1998, c. 18, Sched. I, s. 36; 2009, c. 33, Sched. 22, s. 5 (2).” 

“Order to remove 

(2) If any substance or matter is deposited, thrown or discharged in a lake or river or on the 

shore or banks of a lake or river in circumstances that the Minister considers conflict with the 

purposes of this Act, the Minister may order the person who did the act or caused it to be done 

to take such steps, within the time specified in the order, as the Minister considers necessary 

to remove the substance or matter from the lake or river or the shore or bank, as the case may 

be. 1998, c. 18, Sched. I, s. 36; 2009, c. 33, Sched. 22, s. 5 (2).” 

http://www.e-laws.gov.on.ca/html/statutes/english/elaws_statutes_90l03_e.htm#BK31 

9


March 30, 2013 

Within the Aquatics baseline Report, it has been identified that there is a dramatic 

elevation in heavy metals in Springpole compared to what is approved in Provincial 

Water Quality Objectives (PWQO) (Section 4.4). GCU has been conducting 

exploratory drilling in Springpole for many years, which strongly supports the 

possibility that GCU drilling activities are polluting Springpole. 

If GCU activities are found to increase the heavy metal content in Springpole and 

surrounding lakes, they will be in direct violation of the Lakes and Rivers Improvement Act. 

Relevant Acts that are missing from GCU ESR but are not limited to: 

Ontario Water Resources Act 

Ontario Heritage Act 

Expropriations Act 

Ontario Road Access Act 

Federal Species At Risk Act – vascular plants and mosses 

Ontario Endangered Species Act – vascular plants and mosses 

3.2 Ontario Water Resources Act 

As previously discussed within the Lakes and Rivers Improvement Act, there is a 

responsibility of the proponent to ensure that lakes and rivers are not contaminated by 

their activities. In addition to that, given that Springpole and surrounding lakes provide 

drinking water tourist operations and private land-owners, there is an additional 

requirement that the pristine lakes are kept free of contaminants. Given the Preliminary 

Economic Assessment (PEA) was completed after the ESR submission by GCU, there is no 

discussion of how such matters as “dike construction”, “dewatering” and “open pit 

development” will be addressed within the context of existing water regulations. 

Ontario Water Resources Act: Water, 2011, c. 9, Sched. 27, s. 36 

“Purpose 

0.1 The purpose of this Act is to provide for the conservation, protection and 

management of Ontario’s waters and for their efficient and sustainable use, in order to 

promote Ontario’s long-term environmental, social and economic well-being. 2007, c. 12, 

s. 1 (1).” 

“Examination for pollution 

(2) The Minister may examine any surface waters or ground waters in Ontario from 

time to time to determine what, if any, pollution exists and the causes thereof. R.S.O. 1990, 

c. O.40, s. 29 (2).” 

“Injunction to prevent pollution of water 

(3) Where any person is discharging or causing or permitting the discharge of any 

material of any kind into or in or near any waters that, in the opinion of the Minister, may 

impair the quality of the water in such waters, the Minister may apply without notice to the 

Superior Court of Justice for an order prohibiting such discharge for such period not 

exceeding twenty-one days and on such terms and conditions as a judge considers proper, and 

such order may, on application to the Court, be continued for such period and on such terms 

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March 30, 2013 

and conditions as a judge considers proper. R.S.O. 1990, c. O.40, s. 29 (3); 2001, c. 9, Sched. G, 

s. 6 (50).” 

“Discharge of polluting material prohibited 

30. (1) Every person that discharges or causes or permits the discharge of any 

material of any kind into or in any waters or on any shore or bank thereof or into or in any 

place that may impair the quality of the water of any waters is guilty of an offence. R.S.O. 

1990, c. O.40, s. 30 (1).” 

“Ministry to be notified when polluting material is discharged or escapes 

(2) Every person that discharges or causes or permits the discharge of any material of 

any kind, and such discharge is not in the normal course of events, or from whose control 

material of any kind escapes into or in any waters or on any shore or bank thereof or into or 

in any place that may impair the quality of the water of any waters, shall forthwith notify the 

Ministry of the discharge or escape, as the case may be. R.S.O. 1990, c. O.40, s. 30 (2); 2006, 

c. 19, Sched. K, s. 3 (2).” 

http://www.e-laws.gov.on.ca/html/statutes/english/elaws_statutes_90o40_e.htm#BK47 

3.3 Ontario Heritage Act 

The Ontario Heritage Act is designed to help protect heritage properties and archaeological 

sites. Under the Act, there are provisions to protect areas of historic, architectural 

archaeological, recreational, aesthetic, natural and scenic interest. 

Springpole and surrounding areas are of archaeological, recreational, aesthetic, natural and 

scenic interest to local stakeholders and First Nation communities. Hence provisions under 

the Ontario Heritage Act, should be issued to protect the valued sites located in Springpole 

and surrounding areas. Below is the excerpt from the Ontario Heritage Act confirming the 

above statement; 

Ontario Heritage Act: Part II – Ontario Heritage Trust, 2009, c. 33, Sched. 11, s. 6. 

7. The objects of the Trust are, 

(a) to advise and make recommendations to the Minister on any matter relating to 

the conservation, protection and preservation of the heritage of Ontario; 

(b) to receive, acquire and hold property in trust for the people of Ontario; 

(c) to support, encourage and facilitate the conservation, protection and 

preservation of the heritage of Ontario; 

(d) to preserve, maintain, reconstruct, restore and manage property of 

historical, architectural, archaeological, recreational, aesthetic, natural 

and scenic interest; 

(e) to conduct research, educational and communications programs necessary for 

heritage conservation, protection and preservation. R.S.O. 1990, c. O.18, s. 7; 

2005, c. 6, ss. 1, 5. 

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March 30, 2013 

http://www.e-laws.gov.on.ca/html/statutes/english/elaws_statutes_90o18_e.htm 

The Springpole and surrounding areas belong to the traditional lands of many First 

Nation communities including; Cat Lake, Slate Falls, Lac Seul and Wabaskang First 

Nations. The area also belongs to Treaty 3 of which Cat Lake and Slate Falls First 

Nations are signatory to. Archaeological studies conducted by GCU has identified two 

locations near areas of cultural significance to First Nation communities; Birch River 

crossing and south of Dole Lake. Given that GCU has not provided any Archaeological 

Technical Report for stakeholders to review, and it is stated repeatedly throughout the ESR 

that more archaeological studies are required, it is logical to conclude that the 

archaeological study is incomplete and grossly underestimates the heritage value of the 

region. 

http://www.e-laws.gov.on.ca/html/statutes/english/elaws_statutes_90e26_e.htm#BK6 

Note: In addition to the water quality issues discussed in the ESR it should be noted 

that no where does GCU identify or address water quality issues regarding the 

construction phase of the eastern corridor project. Furthermore, GCU does not 

reference water quality issues pertaining to Springpole exploration related activities 

such as dike construction, dewatering or open pit development all of which are 

suggested in the March 25, 2013 preliminary economic assessment. 

Recommendation: GCU needs to fully disclose ALL potential water related activities 

associated with eastern corridor development or Springpole exploration. Once identified, 

GCU needs to further outline all water quality issues potentially resulting from those 

projects/activities, without drawing bias conclusions regarding their “significance”. 

Recommendation: GCU needs to provide a preliminary rehabilitation and closure plan, 

that specifically addresses costs associated with all water related activities and 

contamination, both locally and downstream. 

Recommendation: GCU needs to conduct a down-stream and long-term water quality 

impacts assessment, that investigates local and regional impacts to surface and ground 

water quality, changes to hydrology, impacts to terrestrial and aquatic wildlife, impacts to 

local tourism and impacts First Nation traditional land use and Treaty rights. 

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March 30, 2013 

4 Class Environmental Assessment & Unresolved Environmental Issues 

The rationale for identifying the GCU road project as Class C rather than a Class D 

undertaking, is not clear, as there are far reaching impacts of this road proposal that have 

yet to be addressed. 

As previously discussed, GCU intends to clear 645 km 2 of land for corridor use: A fact 

that was not clearly identified within the ESR. The environmental impact assessment 

conducted, was not specific for the road project, and failed to assess any areas close to 

where the road is proposed. Given that 645 km 2 of land is to be cleared, it is imperative 

that a full environmental assessment be conducted for the specified project and areas of 

impact. 

Table 2: Considerations for Class C vs Class D Environmental Assessment (OMNR Resource 

Stewardship & Facility Development Projects, page 26). 

Class C considerations 

Class D considerations 

 

 

 

 

 

 

Medium to high potential for significant net 

negative effects 

There is some uncertainty associated with 

predictions of effects, requiring additional 

research and/or evaluation 

The appropriate type of management 

direction is in place for the project, but it does 

not fully define the project, or the plan 

suggests that alternatives should be 

considered or additional evaluation carried 

out 

If a project is proposed when the appropriate 

type of management direction is not in place 

(see Section 2) 

Effects require mitigation techniques tailored 

to the project 

Potential to reduce negative effects or 

increase public understanding by examining 

alternatives 

 

 

 

 

 

 

Several inter-related aspects that have high 

potential for either net positive or negative 

environmental effects that may conflict, 

suggesting a complex situation 

Potential for serious negative effects on 

species at risk 





other alternatives 

Involves a new or contentious interpretation 

of management direction or other MNR policy 

A distinct benefit can be derived from the 

process requirements of Part II of the EA Act, 

including Terms of Reference, formal 

government review and a decision by the 

Minister of the Environment (or the 

Environmental Review Tribunal) 

There are many environmental issues specific for construction, operation and maintenance 

of a corridor which need to be addressed. In this instance there are a variety of 

compounding factors, which require a more thorough examination of the socio-economic 

and environmental implications of this project; 

The corridor will traverse through and fragment endangered woodland caribou 

habitat; 

Increased predation and hunting will occur in the area as a result of the corridor, and 

increase hunting and predation pressure on moose, woodland caribou, large 

furbearers, etc; 

Eastern corridor will destroy 645 km 2 of old growth boreal forest; 

Impacts to water quality through increased sedimentation Birch River crossing; 

Impacts to critical fish spawning habitat at Birch River crossing; 

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March 30, 2013 

 

 

 

 

 

Increased all season access to pristine lakes which will increase fishing and hunting 

pressures in the area; 

Loss of remote tourism business for local tourist outfitters; 

Noise and light disturbance to wildlife; 

Increased number of wildlife vehicle strikes; 

Infringement on First Nation Aboriginal and Treaty rights. 

Due to yet unresolved environmental and socio-economic impacts that the proposed 

eastern corridor will cause, this project requires an independent environmental 

assessment under a Class D EA. 

A part II order is being requested, in order to facilitate the required environmental 

assessment for the project. 

Recommendation: That the OMNR issue a PART II ORDER and require GCU to complete a 

separate Class D Environmental Assessment for the eastern corridor project. 

4.1 Good Neighbour Policy 

The development and implementation of a “Good Neighbour Policy” by GCU was referenced 

within the ESR (Table 3-2, page 31). No follow-up actions by GCU have been pursued to 

develop and implement this document, which would help mitigate some concerns raised by 

stakeholders. 

If the eastern corridor is to proceed, the “Good Neighbour Policy” needs to be developed in 

conjunction with stakeholders, and uphold all the principles laid out within. There is 

currently no indication of when the document will be completed, who will draft it and how 

it will be upheld. 

The Good Neighbour Policy requires the following but is not limited to; 

Be referenced in all future GCU related documentation pertaining to Springpole 

exploration, including within all permits issued by OMNR; 

Outline a communications strategy between Stakeholders, GCU and OMNR; 

Outline compliance measures; 

Account for socio-economic and environmental issues raised by Stakeholders; 

Outline compensation and accommodation measures for Stakeholders in the event of 

economic loss due to GCU related activities; 

Outline reporting schedule for environmental monitoring studies from GCU to 

Stakeholders; 

Have a single document containing all guidelines and activities for environmental 

monitoring schedules, methodology, analysis, reporting, etc; 

Outline decommissioning process of the eastern corridor; 

How to address continued concerns raised by Stakeholders, First Nation 

communities and interested parties. 

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March 30, 2013 

Recommendation: That GCU develop and implement a “Good Neighbour Policy”, in 

conjunction with Stakeholders, prior to approval of the eastern corridor project. 

Recommendation: The “Good Neighbour Policy” should stay in effect for the duration of 

Springpole exploration activities, independent of GCU ownership. 

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March 30, 2013 

5 ESR and Technical Report Deficiencies 

This review of the ESR is done so, with the intention of identifying study deficiencies and 

gaps in the methodologies used to assess wildlife, eco-sites, archeological sites, soils and 

terrain, vegetation, ground water, cumulative and socio-economic impacts, etc. 

In general the ESR is lacking in technical detail to explain methodologies, data 

interpretation, and statistical analysis of results. Review of the supporting Baseline 

Technical Reports reveals a variety of study deficiencies in the areas of; study 

methodology, types of studies performed, insufficient data collection, irrelevant data 

presentation, statistical analysis and missing data. 

Aside from overall study deficiency, the studies themselves were not conducted in 

locations relevant to assess the socio-economic or environmental impacts of the 

eastern corridor. 

GCU did not adequately engage First Nation communities while conducting the 

baseline study fieldwork and desktop analysis for; terrestrial, aquatic, hydrological, 

meteorological, baseline studies. First Nation communities understand the land and 

can contribute valued traditional knowledge. Hiring one or two First Nation 

individuals does not constitute 1) proper engagement with First Nation 

communities, and 2) utilizing traditional knowledge to ensure protection of the 

environment and traditional land use, Aboriginal and Treaty rights. 

Flawed baseline environmental studies imply that the ESR findings, which are based 

on the environmental studies, are also flawed and incomplete. 

Recommendation: GCU needs to conduct thorough environmental baseline studies in 

conjunction with First Nation communities, and jointly engage with those communities 

throughout the planning, hiring, implementation, analysis and report writing stages of all 

studies. 

5.1 Project Rationale 

Within ESR section 1.3: Purpose and Justification for Project, GCU describes how the 

Springpole Gold Project, not to be confused with the eastern corridor project, will benefit 

the local economy. GCU makes statements that the Springpole Gold Project will lead to 

increased jobs (>500), local manufacturing, increased tax revenue, etc. 

This is all well and good, except for the fact that the economic assessment was not 

completed and published online until March 25, 2013. Therefore the statements made 

within the ESR, released March 2, 2013, regarding project economic benefit are unfounded. 

Furthermore, the ESR submitted is for the eastern corridor, and not the Springpole gold 

project: two very different things. Inclusion of information not directly related to the 

eastern corridor, should be removed from this ESR, as it seeks to convince the reader that 

16


March 30, 2013 

there is more economic benefit to the eastern corridor project, without the evidence; 

economic assessment, to back it up. 

The eastern corridor is not necessary for continued exploration at Springpole by 

GCU, and is being perused to increase Springpole property and GCU stock value. 

In past it was clearly communicated by GCU and MNR that stakeholders (tourist outfitters) 

could only raise concerns pertinent to corridor development, and any reference made to 

exploration activities and their impacts were not entertained. Therefore, in future if GCU is 

to make reference to exploration activities within the ESR, as a means of justifying road 

construction activities, then concerned stakeholders should have the right to comment and 

raise concerns about the full extent of GCU Springpole Gold Project activities. 

Recommendation: GCU needs to remove all reference to Springpole exploration as a 

justification for development of the eastern corridor. If reference is not removed, then 

Stakeholders, First Nation communities, organizations and the public will freely comment 

on all aspects of GCU Springpole related activities as a whole. 

5.2 Study Areas and Corridor Dimensions 

What is not discussed throughout the ESR and Technical Reports, is the total length and 

dimensions of the proposed eastern corridor, nor the exact areas investigated during the 

baseline fieldwork studies. 

In typical ESRs pertaining to roadways or access corridors, there is a full description of the 

length, width and potential impact zone of the corridor, as well as project area description. 

With typical corridor projects, a surrounding impact/buffer zone is established, based on 

the anticipated environmental and socio-economic impacts the project will have. GCU did 

not stipulate in the ESR or Technical Reports that a impact/buffer zone had been 

established. The rationale behind establishing an impact/buffer zone is to mitigate 

potential negative impacts associated with corridor use that may be inflicted upon nearby 

water bodies, land occupants, First Nation traditional use activities, archaeological sites, 

wildlife, protected areas, etc. 

As it pertains to safety, which is a justification for the project, road dimensions should be 

clearly stated. Those who travel along the Wenasaga Road, will notice numerous grave sites 

located along the ditches. GCU does not provide any safety statistics for travel on the 

Wenasaga road. Portions of the Wenasaga road are used by private land-owners, increased 

large truck traffic on that road will inevitably lead to an increased number of collisions and 

wildlife strikes: Which will be compounded if Domtar also uses the same corridor. 

Recommendation: GCU and OMNR need to publish the all-season road safety statistics for 

the Wenasaga road, and include preliminary calculations based on statistics, on what future 

road safety projections might be. 

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March 30, 2013 

Recommendation: The OMNR needs to investigate the safety of the Wenasaga road, and 

determine the large truck allowance for the seasonal corridor. 

5.2.1 Study Area Dimensions 

The below terminology is used throughout the GCU ESR and Technical Reports to describe 

the areas in which field work or desk-top surveys were conducted. For each Technical 

Report, and depending on what was being assessed, study area dimensions differ. Despite 

the fact that there are varied study areas, the same terminology is used throughout all ESR 

documents to describe these areas. 

The maps provided by GCU to depict where the study areas are located are of poor quality 

and have low resolution, limiting ones ability to actually read any land base descriptions. 

Study Area Terminology Used: 

Regional study area 

Local study area 

Study site 

Springpole study area - general 

Throughout the ESR and Technical Reports there is one reference to the actual amount of 

land surveyed for wildlife: It was stated that 81 km 2 was surveyed during the aerial wildlife 

fieldwork study (Draft Springpole Terrestrial Baseline Report 2011 

What is not discussed are the specific land quantums for any of the above listed “study 

areas”, nor rationale to justify/explain the why the area and amount of land was selected. 

In most cases, the field study work was conducted in overlapping locations within 1km of 

the primary Springpole camp site, a location which the drills operate 24 hours a day. 

After review of the study areas used by GCU, it appears as though only small local 

study areas were selected from within the Springpole study area in order to dilute 

the impact of potential findings to make them appear insignificant. 

Furthermore, the location of all the local study areas used to for the baseline studies, 

are located nowhere near the intended corridor. 

Recommendation: GCU needs to explicitly define each study area used within all baseline 

technical reports for which fieldwork and desktop analysis was conducted in, and indicate 

within the ESR where exactly the baseline studies were conducted in relation to the eastern 

corridor. 

Recommendation: GCU needs to conduct a Class D Environmental Assessment specific for 

the eastern corridor. 

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March 30, 2013 

5.2.2 Eastern Corridor Dimensions 

Throughout the ESR there is little discussion of the actual dimensions to be used for the 

anticipated corridor. There is reference to the road having dimensions appropriate for a 

forestry road, however they are not specified. 

Only after requesting the information from GCU, did they indicate that the corridor would 

be 15 m wide by 43 km in length, equalling 645 km 2 in total area to be cleared. It was 

not stated within the ESR nor Technical Reports, on the true extent of land to be cleared by 

GCU for the corridor. 

It was stated that a 500 m buffer zone was used to determine corridor impact to large 

furbearers; woodland caribou, however it is not clear if this same buffer zone was applied 

for other wildlife calculations. 

Recommendation: GCU needs to clearly identify eastern corridor dimensions in all GCU 

eastern corridor related documents, stating that 645 km 2 of land needs to be cleared for the 

project. 

Recommendation: GCU needs to provide an explanation for how the impact/buffer zone 

area was determined. 

5.3 Terrestrial Baseline Report Deficiencies 

The terrestrial baseline studies conducted were intended to assess a limited area within 

the broader Springpole study area, and do not reflect the true environmental conditions. 

Baseline studies are designed to establish what environmental parameters currently exist 

in the area, without industrial pressure, so as to determine the degree of impact that the 

intended industrial activity will introduce. 

The bulk of terrestrial baseline field-work studies were conducted within roughly a 3 km 

radius of the primary Springpole campsite. The primary Springpole campsite is an area of 

high anthropogenic activity and noise, causing it to be a site of environmental disturbance. 

Conducting baseline environmental assessments for wildlife in an area with noisy 

industrial activity, would predisposed the study to finding little wildlife in the area: 

at the outset of the studies, there is already experimental bias introduced. 

The methodology employed for all studies lacks scientific significance and statistical 

analysis: many were only conducted only once, and in an area not reflective of the eastern 

corridor. Therefore, the ESR is misleading in presenting that there will be minimal impact 

to wildlife, as the baseline studies were biased, and fraught with defects as highlighted in 

the corresponding sections below. 

In some instances, the desktop analysis conducted for the entirety of the regional 

project study area, used outdated database information. 

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March 30, 2013 

Aside from using flawed fieldwork methodology to assess terrestrial baseline parameters, 

the study did not take into consideration amphibians, reptiles, mosses and insects. The 

below table summarizes field study information, highlighting how little fieldwork was 

actually conducted: estimate 6.5 days for total terrestrial fieldwork . For all terrestrial 

baseline studies no statistical analysis was conducted, and in most cases only a single 

sampling was collected through fieldwork. 

Table 2. GCU Terrestrial Baseline Study Report fieldwork dates and duration of data 

collection. 

Technical Report Date Area Type Duration 

Terrestrial 

- Lg. Mammals 

- 

- Sm. Mammals 

Feb 5, 2011 

June 23 & 24, 

2011 

81 km 2 

8 days 

The ESR made the following statement regarding environmental affects resulting from the 

eastern corridor: “Based on the information provided in this report and taking into account 

the proposed mitigation measures, the proposed project is not likely to result in any 

significant adverse environmental effects on the terrestrial environment (ESR page 3-2).” 

5.3.1 Large Mammal Survey Deficiencies 

The large mammal survey was conducted to determine baseline levels of moose, woodland 

caribou, wolverine and other large mammals in the Springpole study area. The study was 

conducted over 81 km 2 on February 5, 2011, through a single aerial survey at 300 m above 

ground. 

The aerial survey was conducted in a region that was non-specific for the intended eastern 

corridor, and focused on lands immediately around the western, northern and upper east 

portions of Springpole Lake. For the large mammal survey there is little empirical evidence 

used to draw study conclusions and conduct statistical analysis of findings. 

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March 30, 2013 

5.3.1.1 Moose 

Road access to the project site has “… potential adverse effects … with habitat loss, general 

disturbance, and hunting mortality…”. 

By use of OLT modeling the study concluded that predicted moose densities are considered 

to be low” in the Springpole project area. To further substantiate this position, on February 

5, 2011, the consultant conducted an aerial moose survey in the Springpole project area 

and reported the “sighting of 6 cows and 2 calves, no bulls, no ticks…”. 

Furthermore, GCU acknowledges the project road corridor may lead to potentially greater 

hunting mortalities among moose populations due to more hunting opportunities. The use 

of modeling and aerial surveys in this instance may provide useful information to GCU but 

has lead to erroneous conclusions. 

Empirical data and over thirty years of outfitter presence in the Springpole can ascertain 

that: a) moose populations are healthy in WMU 16A; b) non-resident hunter moose success 

rates for the past 30 plus years has averaged between 60-65%; c) First Nation hunting 

derbies in the Birch Lake/Springpole complex have been highly successful; d) resident 

moose hunters continue application to hunt the area due to large moose populations; and, 

e) floatplane pilots on their daily flight patterns consistently report significant sightings of 

bull, cow and calf moose. 

The conclusion to be drawn: the methodology utilized by GCU was flawed and lead to a 

series of incorrect conclusions. In point of fact, road access to the Springpole Project site 

will have major environmental impacts for the moose populations through the loss of 

habitat, cause general and specific area disturbances and lead to greater animal mortality. 

Flawed study methodology; 

An area map should have been developed in conjunction with First Nations, OMNR 

and stakeholders to determine study boundaries; 

A grid of the study area should have been developed to determine potential areas of 

high and low moose populations; 

Numerous aerial surveys should have been conducted over the determined grid, 

occurring at different times of the year to account for seasonal variation; 

Calving or feeding areas should have also been identified; 

No data or discussion provided on current moose populations in the area; 

No data or discussion provided on moose range; 

No data or discussion provided on potential for increased predation and hunting due 

to eastern corridor; 

Little to no First Nation involvement. 

Recommendation: GCU in conjunction with First Nation communities, needs to conduct a 

thorough moose population study relevant to the eastern corridor, complete with fieldwork, 

statistical analysis and up to date desk-top analysis. 

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March 30, 2013 

Recommendation: Future desktop analysis of moose by GCU must include current data, 

and if the data is not available, GCU must clearly state that it is lacking. 

5.3.1.2 Woodland Caribou 

Woodland Caribou are listed as a “threatened species” both provincially and federally. 

Related to their threatened status is the fact that linear corridors (i.e. Springpole Access 

Corridor Project) have an adverse effect on caribou populations primarily through the 

introduction of easy access points for predatory animals such as bears and wolves. 

To date across Ontario it is estimated that woodland caribou habitat has decreased by 40- 

50% compared to the 1800’s, due to human related industrial activity. Woodland caribou 

have adapted to disturbance by wildfire, however the additional disturbance of human 

activity is an added stress and functionally different than wildfires. 

The key concerns for caribou “protection” rests with adherence to the minimization of the 

“anthropogenic … footprint”, “minimization of habitat loss”, “management of habitat 

arrangement and connectivity”, minimization of density of linear features”, mimimize 

“distribution and productivity of … prey species” and avoid “high use and calving sites…” 

These are the observations reported in the Biological Contraints [sic] Report September 

2012. 

All of the observations and attendant conclusions appear to result from literature 

reviews and/or model projections without the benefit of on-site observations or 

accumulation of empirical data. It does appear this operating model of “armchair 

analysis” will somehow lead to irrefutable observations thereby rendering the 

conclusions as valid. Given the literature survey did not yield any empirical data 

about the woodland caribou, and the potentially negative effects of the access 

corridor, it is quite clear that any and all environmental factors impacting the 

ecology of the woodland caribou must be placed front and center with additional 

studies and surveys prior to the granting of any permit to construct an access 

corridor to the Springpole project site. 

A review of Table 3.4.7 Comparison of road corridor options in the Springpole Lake area with 

regard to environmental effects to caribou clearly shows that both road options will have a 

negative effect on the Woodland Caribou. The Woodland Caribou is a threatened species 

and the granting of a harvesting permit, prematurely, will only serve to push this animal 

into the extinct category. The study concludes “… the potential impacts from habitat loss, 

fragmentation and disturbance can be considered to be negative …”. With permitting of the 

construction of the Springpole Access Corridor it is clear the life of the Woodland Caribou 

will be shortened and shortened dramatically. 

Disturbance statistics for woodland caribou were derived from the Cumulative Effects 

Assessment and Proposal Screening Report (CST-EOI-2012-0801-19/20) of the Churchill 

Caribou Range, produced by the OMNR. This report was not made available with the ESR, 

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March 30, 2013 

and there was no background information provided regarding report interpretation or date 

of publication. 

The baseline study for woodland caribou consisted of a single aerial survey 

conducted on February 5, 2011 and database analysis from sources that were out of 

date and had no data available; 

Aerial survey was not conducted over known woodland caribou wintering, calving or 

refuge areas; 

Aerial survey was not conducted over an area relevant for the eastern corridor 

project; 

Database analysis for woodland caribou was referenced as having little to no 

available data for the study area. 

A thorough woodland caribou study needs to be conducted which takes into account 

the following parameters, relevant to eastern corridor development; 

Churchill woodland caribou herd numbers; 

Caribou herd range of occupancy; calving, refuge wintering areas, etc; 

Range disturbance by eastern corridor; 

Impact on food source; 

Degree of habitat fragmentation resulting from eastern corridor; 

Increased predation, hunting and vehicle kills; 

Cumulative impacts assessment on caribou; forestry, hunting, predation; 

First Nation involvement and traditional knowledge. 

The ESR and Technical Report state that insufficient data was available on woodland 

caribou to make any conclusions about the herd. Therefore, no conclusions 

regarding woodland caribou can be drawn from this study, and impacts to woodland 

caribou resulting from the eastern corridor cannot be regarded as insignificant. 

Recommendation: GCU in conjunction with Stakeholders, First Nation communities and 

the OMNR needs to undertake a thorough environmental assessment of woodland caribou 

within the regional project study area, utilizing areas relevant to the eastern corridor. 

Recommendation: Future desktop analysis of woodland caribou by GCU must include 

current data, and if the data is not available, GCU must clearly state that it is lacking. 

5.3.1.3 Large mammals and furbearers 

Large mammals and furbearers were also assessed using the February 5, 2011 aerial 

survey. No additional follow-up studies were conducted. Empirical data on large mammals 

and furbearers (i.e. gray wolves, black bears, marten, lynx, beaver, muskrat, river otters, 

red fox, fisher) is absent from any reports generated by GCU. 

In the absence of data it is nearly impossible to draw any substantive conclusions about the 

environmental impacts to the flora and fauna in the Trout Forest and, hence, impossible to 

offer any mitigation measures to offset these environmental impacts. Nevertheless, GCU 

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March 30, 2013 

offers “principle mitigation measure designed to reduce the potential adverse effects to 

large mammals and furbearers … to restore the linear corridor and harvested patent 

land to productive wildlife habitat upon closure.” [Emphasis by this writer]. 

GCU will make the “ecology good” in the neighbourhood of twenty years!!! During this time 

period all large mammals and furbearers face a potential reduction in their numbers if not 

in their existence. 


the OMNR needs to undertake a thorough environmental assessment of large mammals 

and furbearers within the regional project study area, utilizing areas relevant to the eastern 

corridor. 

5.3.2 Small Mammal Trapping Deficiencies 

The small mammal survey was conducted by setting up 35 traps over an area less than 


March 30, 2013 


the OMNR needs to undertake a thorough environmental assessment of small mammals 


5.3.3 Bird Survey Deficiencies 

The avian study outlines how fieldwork and preliminary desktop studies were conducted. 

The fieldwork consisted of a breeding bird survey (BBS) and a whip-poor-will survey 

(WPWS). 

For the BBS and WPWS, there are a number of research methodology deficiencies 

identified. Common to both studies, there is no indication within the Terrestrial Baseline 

Study Technical Report of the actual study area dimensions used and justification for their 

selection, aside from what is depicted on the map provided (Figure 3.3: Point Count and 

Song Meter Locations in the Springpole Study Area (2011)). GCU has indicated that survey 

sites were randomly selected, however the bulk of the BBS and WPWS seem to fall in the 

exact same region as all the other terrestrial baseline studies, thereby negating 

randomness. 

Background research for the bird surveys was conducted using desktop analysis of the 

Natural Heritage Information Centre (NHIC) and Ontario Breeding Bird Atlas (OBBA) 

specific for Big Trout Lake. NHIC information was only up to date until 1999 and the OBBA 

information was current up to 2005 and for Big Trout Lake and overlapped with 15WS48, 

15WS49, 15WS58, and 15WS59 of the Springpole “regional study area”. The map 

provided by GCU for the bird surveys did not indicate where 15WS48, 15WS49, 

15WS58, and 15WS59 were located on the map. The technical report clearly states 

that there was no information available from that source for locations 15WS48, 

15WS49, 15WS58, and 15WS59: 

“The Ontario Breeding Bird Atlas (OBBA) had no records of any point counts being 

conducted in the study area (squares 15WS48, 15WS49, 15WS58, and 15WS59) and as 

such, there were no associated bird observations (Terrestrial Baseline Report 2011, 

page 3-6).” 

In essence, the desktop research used to corroborate the fieldwork findings are incomplete 

and not relevant for the study in questionable, and cannot be used as a reputable source 

from which to draw conclusions about bird populations in the area. It was not discussed 

within the “Background Research” portion of the technical report (where the NHIC and 

OBBA were referenced) that the desktop analysis was out of date, and not specific for the 

area in question. 

Example of how outdated and misleading the NHIC and OBBA information is: “Bald eagles 

have been reported to the NHIC as having been in the area 4 times between 1990 and 1999 

(Draft Springpole Terrestrial Baseline Report 2011, page 3-4).” Not only is the reference 

outdated by14 years, bald eagles are common in the Birch Lake and Springpole areas. 

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March 30, 2013 

It should be noted, that database information used to assess the wildlife content of 

the area is out of date, and does not reflect actual species abundance. In essence, 

there is very little empirical data on birds used within the technical report. 

5.3.3.1 Breeding Bird Survey (BBS) Methodology Deficiencies 

This survey was conducted through a single session of 10, 10-minute interval non-fixed 

radial observation periods, equating to 100-minutes of observation time. The technical 

report references the fact that two separate radial observation sessions should have been 

conducted, and only one was conducted due to the 2011 forest fire, and there was no 

follow-up. 

There were two general observation locations from which the study was conducted, having 

a total of 11 observation sites; 8 within 2 km of the primary Springpole campsite and 3 

roughly 36 km southeast of campsite. Only the 3 sites selected that are away from the 

campsite, are near to where the intended road corridor will be implemented. The overall 

methodology used to conduct the breeding bird survey was not written in the technical 

report, only a reference was given for a paper by Konze and McLaren, written in 1997. 

According to Environment Canada: Breeding Bird Survey Statistical Methods, BBS routes 

are generally 24.5 km in length and consist of 50 three minute stops, spaced 0.8 km apart. 

The total number of birds seen or hear within 400 m are recorded. From what was 

described in the technical report, this methodology was not employed. 

Recommendation: GCU should conduct a thorough assessment of birds present in the 

regional study area, ensuring that adequate field-work is performed to overcome the lack 

of current database information. 

Recommendation: When GCU conducts their next bird survey, every effort should be 

made to gather sufficient data in accordance with tested methodologies, that allows for 

statistical analysis. 

5.3.3.2 Whip Poor Will Survey (WPWS) Methodology Deficiencies 

The methodology for this survey involved setting up automated birdcall recording stations, 

which were setup to record for ten minute intervals, every hour between 8:30 pm and 5:30 

am. The two recording stations were located on GCU patented claim area, located less than 

200 m apart and no more than 600 m from the primary Springpole campsite. The WPWS 

was conducted only once on June 17, 2011, and no action was taken to complete the 

second recording session. 

The Whip-poor-will is a threatened species due to habitat loss and fragmentation. 

Currently the OMNR is in the process of developing a species-specific habitat 

regulation and recovery strategy for this species (OMNR: Whip-poor-will, 2009). 

The methodology employed draws into question the validity of findings given that; 

The stations were located close to the primary camp in which there is already a high 

degree of industrial disturbance and noise; 

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March 30, 2013 

 

 

 

 

 

The stations are located close to one another, and there would be a high potential of 

overlap and duplication of observations; 

No stations were located near to where the intended road is planned; 

No stations were located near to other breeding bird survey observation sites 

located roughly 36 km away from the primary Springpole campsite; 

The study was only conducted once, with limited data points; 

No statistics provided to determine accuracy of reporting. 

Recommendation: If the OMNR is in the process of establishing a whip-poor-will specific 

habitat regulation and recovery strategy, GCU should be required to properly conduct a 

whip-poor-will species abundance study and cumulative impacts assessment, gathering 

sufficient information to conduct statistical analysis. 

5.3.3.3 Technical Report Bird Survey Findings 

“an active Bonaparte’s Gull (Larus philadelphia) nesting colony was found at one of the 

point count locations (Figure 3.3). The OMNR considers the nesting colonies of all bird 

species to be significant wildlife habitat (OMNR 2009), and as such they have a list of 

recommended guidelines to follow regarding these features (such as minimum buffer 

distances for disturbance and timing restrictions for construction activities) (Draft 

Springpole Terrestrial Baseline Report 2011, page 3-4).” 

“In addition to those species listed on the NHIC database, the OMNR’s Species at Risk website 

indicated a number of species that have the potential to occur within the study area 

including:black tern (Chlidonias niger – Special Concern), Canada warbler (Wilsonia 

canadensis – Special Concern), Common nighthawk (Chordeiles minor – Special Concern), 

Horned grebe(Podiceps auritus – Special Concern), Monarch butterfly (Danaus plexippus – 

Special Concern), Olive sided fly catcher (Contopus cooperi – Special Concern), Short-eared 

owl (Asio flammeus – Special Concern), and Yellow rail (Coturnicops noveboracensis – Special 

Concern). None of these species were encountered during any field work completed in 

2011 (Draft Springpole Terrestrial Baseline Report 2011, page 3-13).” 



such, there were no associated bird observations (Draft Springpole Terrestrial 

Baseline Report 2011, page 3-6).” 

“The principle potential adverse effects of the Project on migratory birds would be those 


nesting birds during the nesting season (April 1st to August15th) is also a concern. Table 3.2.1 


option and for the harvested patent land area (Draft ESR, page 3-6).” 

“Avian species richness was found to be relatively low within the RSA, which is typical of 

northern boreal forest sites (Draft ESR, page 2-4).” 

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March 30, 2013 

It should be noted, that in cases where there is little to no baseline data, that does not 

indicate that species in that area do not exist, it just means that the data has not been 

gathered yet. 

Given the identified deficiencies with the bird survey methodologies, the findings of 

the Terrestrial Baseline Report 2011 for birds are inconclusive, and cannot be used 

to arrive at the assumption that the project will not impact birds. 

Recommendation: GCU in conjunction with First Nation communities and the OMNR 

needs to undertake a thorough environmental assessment of birds within the regional 

project study area, utilizing areas relevant to the eastern corridor. Special attention should 

be paid to collecting consistent field data, given that current databases for the area do not 

have the required information. 

5.3.4 Vegetative Survey Deficiencies 

GCU plans to harvest 645 km2 of old growth boreal forest (>120 years) that crosses 

through wintering woodland caribou habitat at two separate locations. Old growth forests 

are critical for maintaining ecological diversity and integrity, however they are becoming 

scarce due to poorly managed natural resource harvesting activities; forestry and mining. 

The intent of the vegetative study was to identify eco-regions/sites, near the primary 

Springpole campsite. Background research and desktop analysis for the study involved 

searching the Forest Resource Inventory (FRI) managed by the OMNR (the FRI is only 

current up to 2000) and comparing that data to the OMNRs ecosites concepts (Ecosites of 

Ontario, 2009) 

The study failed to investigate which vascular plants and mosses may be present in the 

area, and did not reference which species may be endangered, threatened, special concern 

or extirpated: list available through Ontario Species at Risk database and OMNR (2004). 

The particular region the GCU seeks to develop is old growth boreal forest, and many of the 

vascular plants and mosses identified for protection may be present and thriving within 

this region. Below is a complete list of Ontario species at risk vascular plants that may be 

present in the area: 

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March 30, 2013 

Table 3. Ontario Species At Risk Vascular Plants identified by the Committee on the Status 

of Endangered Wildlife in Canada (COSEWIC) and Ontario Ministry of Natural Resources 

(2004). 

Endangered Threatened Special Concern Extirpated 

American Ginseng 

Bird’s-foot Violet 

Bluehearts 

Blunt-lobed Woodsia 

Butternut 

Cucumber Tree 

Drooping Trillium 

Eastern Prairie Fringedorchid 

Eastern Prickly Pear Cactus 

Engelmann’s Quillwort 

False Hop Sedge 

Few-flowered Club-rush 

(Bashful 

Bulrush) 

Forked Three-awned Grass 

Gattinger’s Agalinis 

Heart-leaved Plantain 

Hoary Mountain-mint 

Horsetail Spike-rush 

Juniper Sedge 

Large Whorled Pogonia 

Nodding Pogonia 

Pink Milkwort 

Pitcher’s Thistle 

Purple Twayblade 

Red Mulberry 

Scarlet Ammannia 

Showy Goldenrod 

Skinner’s Agalinis 

Slender Bush-clover 

Small-flowered Lipocarpha 

Small White Lady’s-slipper 

Small Whorled Pogonia 

Spotted Wintergreen 

Toothcup 

Virginia Goat’s-rue 

Western Silvery Aster 

White Prairie Gentian 

Wood-poppy 

American Chestnut 

American Water-willow 

Branched Bartonia 

Colicroot 

Common Hoptree 

Crooked-stem Aster 

Deerberry 

Dense Blazing Star 

Dwarf Hackberry 

Goldenseal 

Hill’s Pondweed 

Kentucky Coffee-tree 

Lakeside Daisy 

Round-leaved Greenbrier 

White Wood Aster 

Wild Hyacinth 

Willowleaf Aster 

American Columbo 

American Hart’s-tongue 

Fern 

Blue Ash 

Broad Beech Fern 

Climbing Prairie Rose 

False Rue-anemone 

Green Dragon 

Riddell’s Goldenrod 

Shumard Oak 

Swamp Rose-mallow 

Tuberous Indianplantain 

Illinois Tick-trefoil 

Spring Blue-eyed Mary 

http://www.ontarionature.org/discover/resources/PDFs/id_guides/SAR_brochure.pdf 

5.3.4.1 Vegetative Survey Methodology Deficiencies 

The Terrestrial and Wetland Ecosites of Northwesern Ontario have classified Trout Lake 

Forest ecosites, based on soil and vegetative characteristics: classification conducted 

through photo-interpretation and limited field sub-sampling. 

The vegetative fieldwork study consisted of selecting 23 land plots in order to verify 

outdated FRI data. The vegetative and soil composition of each ecosite was sampled and 

compared to existing FRI data; identified as verified or unclassified. Of the 23 plots 

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March 30, 2013 

sampled, 53% of them were unclassified and did not match up with existing FRI data, 

which was attributed to “lack of accurate data for the current FRI (Terrestrial Baseline 

Report, page 3-3).” 

Overall, there are a variety of areas where the study was deficient; 

All 23 selected ecosites were within a small region of the larger study area, and were 

not representative of the overall study area or the eastern corridor; 

The study failed to determine what vegetative species were present in the area 

through field work; 

No reference made to the forest fire and cumulative impacts to vegetation; 

No discussion regarding harvesting 645 km2 of timber and its impacts on vegetative 

biodiversity; 

No discussion on how the eastern corridor would impact endangered, threatened, 

special concern or extirpated vegetative species; 

No environmental protection and mitigation measures proposed for vegetative 

species at risk; 

No discussion on potentially important wildlife plant food sources that may be 

compromised; 


As with the other terrestrial baseline studies, conclusions were drawn about the low 

impact of the project on terrestrial parameters, based on flawed methodology and lack of 

data: “None of these stands have been found to occur within the RSA, therefore the 

potential environmental effects are considered to be negligible and no mitigation is 

required (Draft ESR, page 3-28).” 

Based on the narrow analysis used to derive these unsubstantiated conclusions, it is 

fair to say that this study was unscientific, poorly conducted and results are 

inconclusive. 

Recommendation: GCU needs to conduct a thorough fieldwork vegetation study in 

conjunction with First Nation communities that documents all ecosites, plant species and 

communities relevant to the eastern corridor. 

Recommendation: During the next vegetation study, GCU will document the plant species 

that are listed in the Ontario Species At Risk - Vascular Plants list, and those that are used 

within First Nation traditional purposes. 

Recommendation: The road closure and rehabilitation plan developed for the eastern 

corridor needs to have all plant communities well documented, and outline how revegetation 

will occur in order to return those sites back to their original states. 

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March 30, 2013 

5.4 Aquatics Baseline Report Deficiencies 

Mining activities cause significant contamination of water resources, and generally proceed 

with little regard for the environment. GCU has been conducting exploration activities in 

Springpole for many years, however their environmental analysis of the area was 

conducted in 2011. Any results generated from the Springpole area aquatics study 

will be biased, as drilling activity on the lake may have already altered aquatic 

baseline values. 

After a preliminary review of the aquatics study and technical report findings, there are a 

few issues pertaining to reporting in the ESR; 

1) The Birch River crossing was not assessed within the Aquatics Baseline Study. The 

site is referenced as being important for all season and spawning habitat for fish. 

“The Birch River has its outflow at the eastern end of Springpole Lake, draining Springpole 

into Fawcett Lake. The Birch River is known to provide some of the most important walleye 

spawning habitat in the study area and may serve as year-round habitat for walleye. Lake 

trout, northern pike and whitefish all likely show seasonal use of the river, as either feeding 

(lake trout, northern pike, whitefish) or spawning (whitefish) habitat. The drainage from 

Cromarty Lake into the southwest corner of Springpole Lake also represents important 

walleye spawning habitat in the study area (Draft ESR, page 2-35).” 

2) The ESR does not discuss surface water results within the ESR, as it is not directly 

related to the eastern corridor. Given that all of the technical report studies were 

conducted at locations not relevant for the eastern corridor, it is only fair that 

surface water results also be analyzed here. 

Surface water results from the Aquatics Baseline Report (page 24); 

Total phosphorus was higher than Provincial Water Quality Objectives (PWQO) 

of 0.02 mg/L at sites; SW-6 (0.026 mg/L) in Q1, SW-9 (0.023 mg/L) in Q2, SW-4 TOP 

(0.022 mg/L), SW-5 TOP (0.032 mg/L), SW-9 (0.049 mg/L), and SW-10 (0.042 mg/L) 

in Q3. 

Dissolved mercury was higher than the PWQO of 0.2 μg/L at sites; SW-3 (0.43 

μg/L) and SW-5 (0.27 μg/L) in Q1, as well as in SW-5 MID (0.29 μg/L) in Q3. 

Total cadmium was higher than the PWQO of 0.1 μg/L (sample hardness 

measured at less than 100 mg/L) at SW-11 (0.4 μg/L) in Q1. 

Total iron surpassed the PWQO of 300 μg/L at sites SW-9 (850 μg/L) and SW-10 

(970 μg/L) in Q3. 

Note: technical report did not indicate where the actual sampling locations were. 

The report indicates that total phosphorous, dissolved mercury, total cadmium and 

total iron are already elevated in the study area. No rationale as to why these 

elements were already elevated in surface water samples within the technical report 

and ESR, particularly the heavy metals; mercury, cadmium and iron. 

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March 30, 2013 

Underwater drilling by GCU has been occurring within the Springpole area for many 

years, without monitoring or environmental assessment. Drilling activities are 

associated with causing increased leaching of heavy metals into water, thus 

potentially explaining why there are higher levels of heavy metals observed within 

Springpole study area. 

http://www.safewater.org/PDFS/resourcesknowthefacts/Mining+and+Water+Pollution.p 

df 

3) Toxicity testing only analyzed 3 surface water sites for acute toxicity to Daphnia 

magna and Oncorhynchus mykiss, using pass/fail assessment. 

Fish were not assessed for high levels of detected phosphorous, mercury, 

cadmium and iron, which were detected as high from surface water analysis; 

Deep water samples were not assessed for acute toxicity to Daphnia magna and 

Oncorhynchus mykiss; 

Reference material used to interpret toxicity results are outdated; 1989, 2000; 

Should have conducted a combination of toxicity tests on varied species; 

o Subchronic toxicity 

o Chronic toxicity 

o Carcinogenicity 

o Reproductive toxicity 

o Developmental toxicity 

o Neurotoxicity 

o Genetic toxicity 

Even though toxicity testing was extremely limited, the technical report made the 

following statement: “Toxicity tests performed on water collected from Springpole Lake 

indicated that it was non-lethal to the species Daphnia magna and Oncorhynchus mykiss, as 

no mortalities were reported. This suggests that Springpole Lake is currently capable of 

supporting a healthy aquatic ecosystem with no acute toxicity (Aquatic Baseline Report 

2011, page 79).” 

As stated previously in this report, lack of data and poor methodology do not provide 

justification to arrive at conclusions not supported by the evidence, as was the case with 

the aquatics baseline studies. 

Aside from water quality issues, there is the potential for deforestation to lead to other 

potential water related issues, causing alteration and destruction to aquatic habitat; 

increased sedimentation, erosion, etc. The below table summarizes all the issues 

identified within the ESR which pose a serious risk to aquatic habitat, and are not 

insignificant. 

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March 30, 2013 

Table 4: Alterations and destruction to aquatic habitat are also predicted in the ESR 

resulting from eastern corridor construction and operation activities (Draft ESR, page 3- 

31). 


Potential stream flow 

alterations may result from: 

Alterations to lake, pond, and 

stream water quality may 

result from: 

Destruction/Displacement of 

Fish Habitat may result from: 

GCU Related Activity 

Increased surface run-off during storm events due the 

clearing of vegetation. The removal of vegetation is 

known to decrease the rate at which water infiltrates 

the soil and increases run-off volumes, making small 

streams/creeks more vulnerable to flooding during 

storm events. 

 

 

 

 

 

Alteration of flow regimes caused by improperly 

installed culverts and addition of aggregates. 

Improperly constructed road crossings are known to 

increase erosion and gradients in downstream areas 

and can also impede flow with insufficient culvert size 

or when improperly installed 

Elevated levels of Turbidity, Total Suspended Solids, 

and Conductivity due to increased levels of erosion 

and sedimentation caused by the removal of riparian 

vegetation. 

Increased water temperatures during the summer 

months due the removal of riparian vegetation may 

increase the solar input to a stream causing water 

temperatures to increase above normal temperatures. 

Furthermore, increased levels of Total Suspended 

Solids caused by sedimentation and erosion also 

increase water temperatures as they retain more solar 

radiation. 

Improperly constructed road crossings will impede 

fish migration and alter substrate type due to changes 

in the flow regime. 

Changes in water temperatures due to erosion and 

sedimentation will affect species that are not resilient 

to warmer temperatures. Increased sedimentation will 

also fill in pools and under-cut banks, as well as 

covering essential spawning habitats such as gravel 

and cobble shoals. 

The mitigation measures proposed by GCU to remedy all the above potential impacts to 

aquatic habitat and flow alterations include implementing a buffer around lakes, ponds and 

streams and having an “experienced and respected professional engineer” as opposed to an 

inexperienced and disrespected unprofessional engineer (!?!?). The mitigation measures 

proposed do not discuss continued monitoring or follow-up actions if any of the above 

impacts are detected. 

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March 30, 2013 

The ESR regards all potential impacts to lakes, rivers and streams to be low, without 

providing any rationale, or having the evidence to back up those claims. 

Recommendation: GCU needs to conduct a thorough aquatics study, taking into account 

the above-mentioned parameters, relevant to all Springpole exploration activities. The 

study should assess the environmental impacts for the duration of Springpole exploration 

project; 10-20 years. 

Recommendation: The next aquatics baseline study performed by GCU needs to take 

information gathered from the hydrology and terrestrial baseline studies and evaluate 

their combined effect on aquatic habitat, surface and deep water quality, species diversity, 

species reproduction, hydrology, etc. 

Recommendation: If GCU has determined that there are high levels of heavy metals 

detected in Springpole, all activities that could potentially contribute to increased heavy 

metal leaching must be stopped. 

5.5 Hydrology Baseline Report Deficiencies 

Hydrology is the study of water movement, quality and distribution. Typical hydrological 

investigations include an assessment of ground water quality, character, composition and 

potential for contamination. The hydrological study conducted by GCU did not evaluate 

any parameters associated with ground water quality, or identify which aquifers may be 

impacted by Springpole drilling activity. 

The aquatics study should have been conducted in conjunction with the hydrology study in 

order to properly assess for downstream or ground water contamination: aquatics study 

revealed that heavy metals were already elevated in Springpole. 

In the Preliminary Economic Assessment released March 25, 2013, GCU states that 

Springpole exploration construction will include: “project infrastructure, dike construction 

and dewatering activities, open pit development, procurement of mining and milling 

equipment, and mill construction (GCU Preliminary Economic Assessment – March 25, 

2013).” 

NO WHERE in the ESR or Technical reports (hydrology or aquatics) does GCU discuss 

dike construction, dewatering activities, open pit development or the required water 

and sewer infrastructure required to pursue continued/advanced exploration, that 

would occur pending approval of the eastern corridor. 

It is evident for the Preliminary Economic Assessment, that GCU is NOT being fully 

transparent about the full scope of the Springpole exploration project, nor the true 

environmental and socio-economic ramifications related to project activities. 

Recommendation: GCU needs to fully disclose ALL Springpole related exploration 

activities, inclusive of the eastern corridor, in a single document complete with technical 

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March 30, 2013 

report findings related to water quality, hydrology, aquatic habitat, terrestrial values and 

socio-economic factors. 


The ESR is comparing the GCU road to natural erosion processes such as fires, implying 

that an industrial corridor used for heavy trucks allows for the development of 

biodiversity. The ESR concludes that timber harvesting results in biological diversity and 

ecological function (ESR page 54). 

Given that the data derived from terrestrial baseline studies and desktop analysis for flora 

and fauna were flawed and incomplete, it stands to reason that no firm conclusions 

regarding habitat fragmentation can be drawn in the ESR. 

For example: Information used to assess woodland caribou habitat is based off of an 

incomplete OMNR study from 2000 and other references that are between 15 and 29 years 

old. ESR discussion of woodland caribou habitat fragmentation is limited and identified as 

not significant. 

Recommendation: GCU needs to complete a thorough terrestrial baseline study that 

specifically addresses all contributing factors to habitat fragmentation for all species, not 

just woodland caribou. The study should evaluate habitat fragmentation resulting over 10- 

20 years, as a result of anticipated Springpole exploration related activities; eastern 

corridor develop and exploration. 

5.7 Environmental Protection and Mitigation Plans 

GCU states that mitigation measures are planned and will proceed with future consultation 

with affected stakeholders. To date there is no information available on what guidelines 

are in place to ensure that consultation with stakeholders will take place, and who will 

mediate any dispute. In general, most environmental issues are regarded as resolved by 

GCU, despite evidence showing that the technical studies used to arrive at those 

conclusions are deficient. 

Table 6-1: Mitigation Measures for Potentially Significant Negative Effects/Concerns, 

proposing a variety of mitigation measures. In order for the mitigation measures to be 

effective the following needs to occur; 

 

 

 

Guidelines for the proposed mitigation measures needs to be developed; 

A communications strategy between Stakeholders, First Nations and GCU needs to be 

developed, whereby all parties are routinely kept informed of all mitigation, monitoring 

and follow-up activities and corresponding reports; 

Monitoring and follow-up procedures need to be developed and corroborate with the 

communication strategy and mitigation measure guidelines; 

The environmental mitigation measures proposed in general simply state that monitoring 

will take place, but no reference is made to follow up activities and communicating findings 

of those monitoring and follow-up programs to Stakeholders, First Nation communities and 

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March 30, 2013 

the OMNR. Wildlife mitigation plans are somewhat proposed in the ESR, but lack 

description, monitoring and follow-up plans. 

Recommendation: GCU in conjunction with stakeholders and First Nation communities 

needs to draft an all-in environmental protection and mitigation plan that addresses all 

environmental issues, and how the monitoring, data analysis/interpretation, report writing 

and mitigation process will take place. 

Recommendation: GCU needs to establish a communications plan with Stakeholders, First 

Nation communities, OMNR and the public, that outlines how issues of environmental and 

socio-economic concern will be addressed, 

5.8 Cumulative Impacts Assessment and Residual Effects 

The cumulative impacts assessment conducted by GCU is completely insufficient, and is 

only referenced in a few locations throughout the ESR; 

page xi “Reduced potential for cumulative effects in the region compared…” 

page 7 “increased potential for cumulative effects to biological values…” 

Table 2-1 “exert greater cumulative effects because it would…” 

Table 2-1 “which creates a larger cumulative impact and affects…” 

 

Table 2-1 “would result in a greater cumulative impact for the region..” 

Page 14 “reduction in the potential for cumulative effects in the region..” 

Table 2-2 “in a greater cumulative impact for the region because…” 

Page 21 “Reduced potential for cumulative effects in the region compared..” 

Page 22 “resultant reduction for cumulative effects in the region…” 

No cumulative impacts assessment was conducted for this project, as is evidenced by a 

complete lack of data available within the ESR and technical reports. GCU discusses their 

alliance with Domtar (Forestry) and road use synergies, but there is no further exploration 

into how joint use of the corridor will impact socio-economic and environmental 

parameters. 

The ESR references a variety of potential environmental impacts to wildlife resulting from 

corridor use and include; 

Mortality as a result of construction; 

Mortality as a result of vehicle collisions; 

Modification of behaviour; 

Habitat fragmentation and loss; 

Displacement due to invasive species; 

Increased predation. 

Areas required for a cumulative impacts assessment for the project; 

Long-term study that evaluates the socio-economic and environmental impacts over 

a ten year period for projected eastern corridor; 

Cumulative assessment needs to consider but is not limited to; 

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March 30, 2013 

o Forestry pressures; 

o Increased traffic; 

o Seasonal and all-season eastern corridor use schedule; 

o Traffic load on seasonal and all-season eastern corridor; 

o Impact of herbicide use by forestry company; 

o Water contamination issues, changes to hydrology, ground water quality, 

aquatic environment, etc. 

o Forest fires and other natural events; 

o First Nation traditional land use, Aboriginal and Treaty rights; 

o Tourism; 

o Wildlife hunting and predation; 

o Invasive species; 

o All mining activities and establishment of a larger Springpole base camp, etc. 

Prior to any project going forward, a thorough cumulative impacts assessment 

should be completed, taking into account the above mentioned parameters. 

Recommendation: GCU complete a thorough cumulative impacts assessment, taking into 

account the above mentioned parameters, that evaluates the long-term impacts of the 

project over the anticipated duration of Springpole exploration; 10-20 years. 

5.9 Future Corridor Upgrades 

In all discussions to date with Stakeholders, GCU has maintained that they are looking to 

build a seasonal winter road. Closer inspection of the ESR indicates that GCU is not being 

fully transparent with stakeholders, First Nations, etc, as the ESR makes reference to 

establishing an all season road. 

“Water crossings along the eastern corridor would be built to a primary road standard 

where possible to facilitate future potential upgrades of the winter operational road to an 

all-weather access road at a later date and also to minimize environmental risk associated 

with less robust water crossing structures (ESR page vii).” 

Gravel placement over this winter operational road and upgrading it to an all-weather 

access road is not part of the currently proposed Project. “Pending continued positive 

exploration results and on-going consultation, the gravel placement that would be 

required to upgrade this winter operational road to an all-weather access road may 

be proposed at a later date (ESR page vii).” 

Recommendation: GCU needs to outline a 10-20 year plan for the Springpole Gold Project, 

inclusive of the eastern corridor, outlining their full intentions for Springpole, the eastern 

corridor and collaborations with other resource harvesting companies; Domtar. 

5.10 GCU and Domtar Synergies 

GCU emphasizes that Domtar may use the eastern corridor at some point in the future, 

without providing specific information as to when; 2014-2019 period. Review of the 

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March 30, 2013 

Domtar 2014-2019 Forest Management map, shows that Domtar is not anticipating to 

harvest in the greater eastern corridor region, during 2014-2019 period. So far it is not 

clear to what extent Domtar will use the eastern corridor. 

GCU is currently seeking a 3 year exploration permit for Springpole. If continued 

Springpole exploration unsuccessful, the permit will terminate Springpole activity in 2016. 

Therefore making the assumption that GCU and Domtar will use the road during the same 

period is premature. 

Furthermore, in the event that GCU and Domtar use the eastern corridor simultaneously, 

another environmental assessment will have to be conducted to evaluate the cumulative 

impacts of dual corridor use. 

Recommendation: GCU be transparent with Stakeholders, First Nation community, OMNR 

and the public regarding the full extent of their synergistic relationship with Domtar, and 

identify the following; 

When synergistic eastern corridor use will take place down to the year; 

How much financial or administrative assistance Domtar is providing to GCU for 

eastern corridor development; 

Outline the road closure and rehabilitation plan in the event share use of the eastern 

corridor. 

Recommendation: GCU needs to provide detailed maps showing the 2014-2019 GCU 

eastern corridor and Domtar harvesting plans, identifying exact locations of where Domtar 

activities will take place in reference to the eastern corridor. 

Recommendation: GCU will need to complete a cumulative impacts assessment for the 

eastern corridor if both GCU and Domtar intend to use the corridor over the same period; 

2014-2019. 

5.11 Corridor Rehabilitation 

When any land is subject to industrial exploitation, leading to environmental degradation, 

an environmental rehabilitation plan (ERP) is required of the proponent to ensure 

accountability. The ERP must employ strategies to restore the environment to its original 

state; structure, properties, topography, texture, etc. Instances where the environmental 

damage is anticipated to be significant, the proponent is required to set-aside a reclamation 

bond” with the OMNR, to cover costs associated with project decommissioning and 

rehabilitation. 

The eastern corridor intends to destroy 645 km 2 of old growth boreal forest, crossing 

through known woodland caribou habitat. Despite the rather large project area, the ESR 

makes no direct reference to having a rehabilitation strategy or plan in place, and 

instead puts the responsibility onto First Nations, Domtar, Stakeholders and OMNR. 

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March 30, 2013 

“This rehabilitation that GCU is prepared to undertake is pending input from other parties 

that include, but are not limited to, Cat Lake First Nation, Domtar and MNR. It is 

understood that some of these parties may potentially have an interest in having some or 

all of the road and water crossings remaining in place. This modified use of the eastern 

corridor would be subject to a new environmental assessment and approvals process (ESR 

page 49).” 

GCU further avoids addressing the issue of eastern corridor rehabilitation directly, by 

stating that: “In the event that the Springpole Gold Project becomes fully permitted and 

proceeds to a production phase, the rehabilitation of the access corridor would be within the 

scope of the Closure Plan that is filed pursuant to Part VII of the Mining Act and MNDM’s 

requirements regarding the financial assurance provision for the entire development (ESR 

page 49).” 

Review of Part VII of the Ontario Mining Act provides no specific recommendations 

for corridor rehabilitation. Given that GCU seeks to implement a road through 645 

km 2 of valued forest, Stakeholders are requesting the GCU be required to place a 

“Reclamation Bond” for 100% of the rehabilitation costs with the OMNR. GCU must 

also disclose the total amount required for rehabilitation of 645 km 2 of land to 

Stakeholders, First Nation communities, etc. 

Note: According to the Springpole Preliminary Economic Assessment, roughly $20 million 

is planned to be set aside for Springpole mine closure and rehabilitation: No indication of 

how much reserved for eastern corridor rehabilitation. To date, GCU has not indicated how 

much it will cost to put in a seasonal road, nor the amount required to rehabilitation 645 

km 2 of land. 

This raises serious questions of whether GCU understands how much it will cost to 

rehabilitate the eastern corridor, timelines associated with rehabilitation and if they 

even have the financial capital sufficient for the undertaking. 

If the eastern corridor is constructed, and GCU lacks the capital to initiate 

rehabilitation, tax payers will end up covering the cost! 

Recommendation: The OMNR require that GCU secure a reclamation bond for 100% of 

the costs associated with rehabilitation of the eastern corridor. 

Recommendation: The OMNR and GCU will disclose to Stakeholders, First Nation 

communities and the public the amount required to rehabilitate 645 km 2 of old growth 

boreal forest and woodland caribou habitat. 

Recommendation: GCU develop a road closure and rehabilitation plan for the eastern 

corridor in conjunction with Stakeholders, First Nation communities and the public, which 

is to be developed prior to approval of the project. 

39


March 30, 2013 

5.12 GCU Preliminary Economic Assessment and Stock Volatility 

Stakeholders are concerned that GCU will not have sufficient funds to cover the costs 

associated with rehabilitation of the eastern corridor in the event that Springpole 

exploration is no longer viable. 

The GCU Preliminary Economic Assessment was released on March 25, 2013; 1 week prior 

to final submission for ESR comments. The following is the indicated and inferred gold and 

silver mineral resource identified at Springpole to date: 

GCU: Management Discussion & Analysis, August 31, 2012, page 7: 

Classification Tonnage 

(million 

metric 

tonnes 

Gold Grade 

(grams per 

tonne) 

Silver Grade 

(grams per 

tonne) 

Gold 

Contained 

(million troy 

ounces) 

Silver 

Contained 

(million troy 

ounces) 

Indicated 128.2 1.07 5.7 4.41 23.8 

Inferred 25.7 0.83 3.2 0.69 2.7 

Based on the below information extrapolated from GCU documents posted on the GCU 

website (www.goldcanyon.ca), Stakeholders would like to know if the below references to 

company evaluation are correct and if sufficient funds are available to pursue road 

construction, operation, environmental monitoring and rehabilitation activities? 

Q3-Financial Statements, Nine Month Period Ended August 31, 2012: 

According to the most recent financial statement issued by GCU as of August 31, 2012, the 

3 rd quarter statement indicates GCU has $11,493,769.00 (Cdn) working capital, $12, 

749,732.00 (Cdn) cash and $24,450,978. 00 (Cdn) accumulated deficit. 

“Going Concern of Operations: The Company has not generated revenue from 

operations. The Company incurred a net loss of $3,340,521 during the nine months 

ended August 31, 2012 and an accumulated deficit of $24,450,978. As the Company is in 

the exploration stage, the recoverability of the costs incurred to date on exploration 

properties is dependent upon the existence of economically recoverable reserves, the ability of 

the Company to obtain the necessary financing to complete the exploration and development 

of its properties and upon future profitable production or proceeds from the disposition of the 

properties and deferred exploration expenditures. The Company will periodically have to 

raise funds to continue operations and, although it has been successful in doing so in the past, 

there is no assurance it will be able to do so in the future (Q3-Financial Statements, Nine 

Month Period Ended August 31, 2012, page 8).” 

Investors have raised concerns regarding weak GCU share price (April 1, 2013: 

$0.48/share) and higher than normal trading volume. GCU has also made public that the 

company only has $10 million (Cdn) in reserve (an amount that would barely cover 

summer operation costs) and does not communicate the $24,450,978.00 in accumulated 

deficit. Below are recent excerpts from GCU’s website (www.goldcanyon.ca - accessed April 

1, 2013). 

40


March 30, 2013 

Note: the Preliminary Economic Assessment does not comment on the $24,450,978 

accumulated deficit. 

February 6, 2013 – Gold Canyon Comments on Recent Share Price and Trading 

Volume Concerns: 

“In response to enquiries, Gold Canyon Resources Inc. (TSX VENTURE:GCU) 

(PINKSHEETS:GDCRF) ("Gold Canyon" or "the Company") wishes to comment on the 

Company's recent share price weakness and higher than normal trading volume, 

which over the past several months has raised concerns amongst its investors 

(www.goldcanyon.ca - Accessed April 1, 2013).” 

“Gold Canyon has cash reserves of more than (Cdn)$10 million, considered to be 

sufficient to fund current operations through the short to medium term without the 

immediate need to raise more capital. In the circumstances, management believes that 

Gold Canyon's current share price significantly undervalues the Company, and with the 

support of Gold Canyon's board of directors, is currently examining various initiatives and 

strategic options to remedy this situation (www.goldcanyon.ca - Accessed April 1, 2013).” 

There is a strong possibility that GCU requires the eastern corridor to build 

Springpole property value, improve investor confidence and increase stock price, in 

order to afford continued exploration at Springpole. 

If this is the case, then the eastern corridor is NOT required to directly facilitate 

exploration at Springpole. 

In the event that eastern corridor development is approved and GCU stocks continue 

to fall, financial hardship will prevail, leaving the company without the financial 

means to rehabilitate the eastern corridor. Unless a reclamation bond is secured 

prior to GCU commencing eastern corridor development, there is a strong possibility 

that tax payers will have to cover the eastern corridor rehabilitation costs: which 

will be much more than $10 million. 

Recommendation: GCU needs to fully disclose the amount of working capital and 

accumulated deficit to Stakeholders, First Nation communities, the public and OMNR prior 

to approval for the eastern corridor. 

Recommendation: If GCU is working jointly with Domtar on the development of the 

eastern corridor, it should be fully disclosed to what extent and how much financial 

assistance Domtar will provide for rehabilitation of the eastern corridor. 

41


March 30, 2013 

6 Summary of Recommendations 

 

 

 

 

 

 

 

 

 

GCU needs to complete a thorough environmental assessment for all environmental 

parameters; terrestrial, aquatic, hydrological, etc, utilizing tested methodologies 

that allow for reproducibility and statistical analysis. 

GCU needs to conduct thorough environmental baseline studies in conjunction with 

First Nation communities, and jointly engage with those communities throughout 

the planning, hiring, implementation, analysis and report writing stages of all 

studies. 

All environmental studies conducted must be done so in conjunction with First 

Nation communities and OMNR, and assess the environmental impacts associated 

with all aspects of Springpole exploration over the course of 10-20 years; 

anticipated period of operations. 

GCU needs to conduct an all-in cumulative impacts assessment for all environmental 

parameters, investigating the long-term impacts (10-20 years) of GCU Springpole 

exploration activities. 

GCU needs to establish the following documents in conjunction with Stakeholders, 

First Nation communities, OMNR, environmental organizations, etc; 

o Good Neighbour Policy 

o All-in Environmental Protection and Mitigation Plan 

o All-in Water quality, hydrology, aquatic habitat and terrestrial implications 

analysis 

o Eastern corridor rehabilitation plan 

GCU needs to provide an all-in document outlining their current and anticipated 

financial constraints as it relates to all Springpole related activities, highlighting 

overall stock weakness, incurred debt, available cash, assets, etc. 

OMNR should require GCU to secure a reclamation bond for 100% of the costs 

associated with closure and rehabilitation of the eastern corridor. 

OMNR should not permit GCU for eastern corridor development based on; 

o Incomplete environmental assessment 

o Lack of transparency with financial instability of the company 

o Poor rationale to pursue the project 

In the event that OMNR wants to pursue approval of the GCU eastern corridor 

project, a PART II ORDER should be implemented, elevating the project to a Class D 

Environmental Assessment, thereby requiring an independent and thorough 

environmental assessment. 

42

APPENDIX 9 

9B: FINAL RESPONSE TO 

SUBMISSION FROM TROUT 

FOREST TOURISM OPERATORS ON 

FINAL ESR DATED FEBRUARY 2013

GOLD CANYON RESOURCES INC. 

GCU: TSX-V 

Suite 810 - 609 Granville Street, P.O. Box 10356 Pacific Centre, Vancouver, B.C., Canada V7Y 1G5 

Tel: (604) 682-3234 Toll free: 1 (888) 242-3234 Fax: (604) 682-0537 

www.goldcanyon.ca 

April 19, 2013 

Chief Matthew Keewaykapow, Cat Lake First Nation 

Chief Lorraine Crane, Slate Falls First Nation 

Chief Clifford Bull, Lac Seul First Nation 

Chief Leslie Cameron, Wabauskang First Nation 

Mr. Jim Bradley, Minister of the Environment 

Mr. Michael Chan, Minister of Tourism, Culture and Sport 

Mr. Michael Gravelle, Minister of Northern Development and Mines 

Mr. Dave New, Ministry of Natural Resources, Area Supervisor, Red Lake South 

SENT VIA EMAIL ONLY 

Re: Response to Trout Forest Tourist Outfitters Final Environmental Study Report Review 

We write to respond to the submission dated 30 March 2013 from the Trout Forest Tourist 

Outfitters (“TFTO”) titled Gold Canyon Resources Inc.: Final Environmental Study Report Review 

(the “TFTO Submission”). The TFTO Submission is seriously flawed and, therefore, should be 

given very little, if any, weight when assessing Gold Canyon Resources Inc.’s (“GCU”) 

Environment Study Report for the Springpole Gold Access Corridor Project (“Project”). 

Our main concerns with the TFTO Submission are as follows: 

1. Many of the concerns relate to the development of the Springpole gold mine 

project (“Gold Project”), rather than the Project, and are not within the scope of this 

review. A further comprehensive review of the mine development would be 

undertaken if the Gold Project advances to that stage. 

2. TFTO’s concerns related to the Project are based on factual errors, 

misunderstandings, and mischaracterizations. The resulting conclusions that 

TFTO asks the Ministry to draw are extreme and beyond any reasonable 

understanding of the nature and scale of the Project. Moreover, those conclusions 

lack any evidentiary or logical foundation. 

3. GCU’s consultation efforts are not accurately reflected. GCU undertook extensive 

consultation, including with the TFTO. GCU listened carefully to all reasonable 

concerns raised and adjusted the design of the Project in response. 

4. TFTO uses inflammatory language that is unwarranted and then distributed the 

TFTO Submission broadly in an effort to raise concerns among others. TFTO 

refers to “stakeholders” in numerous paragraphs and purports to represent a broad 

view of such stakeholders. It is unfortunate that TFTO has chosen this approach. 

TFTO can only speak for its members. GCU has always been open and 

forthcoming with information to explain the Project with all interested stakeholders.

Page 2 

GCU began consulting with TFTO in 2012. In early 2013, GCU asked TFTO to identify any 

issues that remained unresolved for the TFTO. TFTO identified three outstanding concerns that 

are all addressed in the ESR, but the focus of TFTO members was asking GCU to provide 

economic compensation or buy their operations, which in most cases are far from the Project 

vicinity. GCU has declined to buy any operations of TFTO members, but has remained open to 

discuss any reasonable outstanding concerns about impacts of the proposed road. 

The balance of this letter elaborates further to put the Project and the TFTO Submission into 

proper context. A more detailed response to the TFTO Submission is attached. 

The Project 

GCU’s Springpole Gold Access Corridor Project (the “Project”) involves the construction of an 

already approved forestry road (~22 km) and a short-term, restricted access winter road (~21 km) 

on lands that will be leased, pursuant to Section 81 of the Mining Act. The proposed road corridor 

is illustrated on Figure 2-1 of the final ESR. Contrary to the original TFTO Submission, the area 

to be cleared for the Project consists of only 0.645 km 2 , rather than 645 km 2 , and approximately 

0.33 km 2 of that area is already approved to be cleared in the Trout Lake Forest Management 

Plan. 1 

The proposed road will allow the safe and efficient exploration work necessary to further define 

the mineral resource on the Springpole Gold Project, currently known to host more than five (5) 

million ounces of gold and 26 million ounces of silver. This Project goes no further. The results of 

the work to define the mineral resource will lead to a further decision on whether the Gold Project 

would proceed to the environmental assessment review stage: 

• If the Gold Project proceeds to the environmental assessment review stage, a 

comprehensive environmental assessment would be initiated to assess the Gold Project 

from its development to it ultimate decommissioning. 

• If Gold Project does not proceed – and, specfically, GCU does not initiate a provincial 

environmental assessment for the Gold Project before 2017 – then the portion of the 

proposed road beyond the forestry road will be decommissioned in accordance with the 

MNR’s modern best practices, as described in Section 5.3 of the Final ESR. GCU will 

provide financial assurance to the Crown to support any such decommission work as a 

condition of this environmental assessment process. 

The Project is a road corridor development; a type of undertaking that has been commonplace in 

Ontario for more than 50 years. The environmental protection measures for road development are 

well understood and proven, having been integrated into numerous EA processes and projects 

across northern Ontario. The Project incorporates best practices and additional site-specific 

measures to further mitigate potential impacts to biological values. In addition, GCU proposes to 

decommission historic mineral exploration trails in the region. 

Consultation with Stakeholders 

GCU has consulted local stakeholders, including the TFTO, since April 2012 regarding the 

Project. GCU has modified the Project design and adopted specific mitigation measures to 

respond to stakeholder concerns. 

1 TFTO filed a revised submission to correct this significant error, but the value was still miscalculated.

Page 3 

GCU’s mitigation measures are more substantive than those that have been adopted 

in other northwestern Ontario Sustainable Forest Licences to address the same suite of concerns 

that have been expressed by remote tourism operators. GCU’s mitigation measures represent a 

substantial accommodation, in good faith, of the TFTO concerns. 

The TFTO Submission 

The TFTO Submission outlines four general objectives on page 5, section 1.1. Our brief 

response to each of those stated objectives follows: 

TFTO Stated Objective 

1: “To highlight the fact that GCU did not 

conduct the required baseline environmental 

studies from which the eastern corridor ESR 

was drafted, in order to gain OMNR approval 

for the project”. 

Response 

GCU has hired qualified, independent 

consultants to conduct baseline environmental 

studies with direct participation of First Nation 

technicians. The baseline environmental work 

surpasses what is typically required for an 

environmental assessment for a road corridor 

of this scale. 

The baseline environmental studies identify 

values that should be avoided by the road 

corridor (see Figure 2-1 of the final ESR). 

Those studies also document the current 

conditions in the region used in the impact 

analysis for the winter road. That analysis is 

presented in Appendix 4 of the final ESR. It is 

important to note that the TFTO submission 

does not identify any material deficiency with 

the analysis in Appendix 4. 

2. “That the project will have far reaching 

environmental impacts, and a more thorough 

environmental and socio-economic analysis is 

required prior to project approval.” 

3. “To request a Part II Order to elevate the 

Environmental Assessment requirements for 

this project from a Class C to a Class D” 

4. “Require that GCU provide a Reclamation 

Bond with the OMNR to ensure that money is 

available for land rehabilitation.” 

The Project proposes a short duration winter 

road, with construction and use as described 

in the Final ESR. The TFTO Submission 

speculates on potential impacts without any 

supporting evidence. In doing so, TFTO 

attempts to draw in impacts that do not relate 

to the road. If GCU seeks to develop the Gold 

Project, then a comprehensive environmental 

assessment will assess the impacts and 

benefits of such development. 

GCU believes the current process is effective 

to assess the impacts of the proposed Project, 

and is consistent with similar projects in 

Ontario. There is simply no evidentiary basis 

to support the TFTO request to elevate the 

ESR review to Class D. 

GCU has proposed sufficient financial 

assurance as a condition in Section 5.3 of the 

final ESR.

Gold Canyon Resources Inc: Final 

Environmental Study Report Review 

Trout Forest Tourist Outfitters 

March 30, 2013 

This report is the property of Meaghan Labine, Harald Lohn, Vic Davies and 

Peter Kay, and any use of contents requires approval from all parties. 

ABSTRACT 

This report outlines the major concerns and deficiencies identified with Gold 

Canyon Resources Final Environmental Study Report and corresponding 

Baseline Technical Reports, as identified by Trout Forest Tourist Outfitters.


Contact Information 

March 30, 2013 

Meaghan Labine BSc, MSc, PhD Candidate 


info@birchlakelodge.com 

Harald Lohn BSc, MPA, MSW 

KaBeelo Lodge 

kabeelo@integra.net 

Vic Davies 


fishcanada@nwonet.net 

Peter Kay 

KayAir Service & Outposts 

karenk@nwconx.et 

Please note: that the authors do not intend to speak on behalf of affected First Nation 

communities; Cat Lake First Nation, Slate Falls First Nation, Lac Seul First Nation and 

Wabauskang First Nation. We respect the individual concerns and rights of local First 

Nation communities, and only seek to support and help ensure that their traditional land, 

Aboriginal and Treaty rights are respected and upheld. 

2



March 30, 2013 

1 Overview .......................................................................................................................................... 4 

1.1 Report Objectives .............................................................................................................................. 5 

1.2 Stakeholders and First Nation Communities .................................................................................... 5 

2 Springpole Eastern Corridor Conflicts ................................................................................... 7 

2.1 Project Timeline ................................................................................................................................ 7 

2.2 Major Concerns Identified by Stakeholders...................................................................................... 7 

3 Federal and Provincial Policies ................................................................................................ 9 

3.1 Ontario Lakes and Rivers Improvement Act ..................................................................................... 9 

3.2 Ontario Water Resources Act ......................................................................................................... 10 

3.3 Ontario Heritage Act ....................................................................................................................... 11 

4 Class Environmental Assessment & Unresolved Environmental Issues .................. 13 

4.1 Good Neighbour Policy ................................................................................................................... 14 

5 ESR and Technical Report Deficiencies ............................................................................... 16 

5.1 Project Rationale ............................................................................................................................. 16 

5.2 Study Areas and Corridor Dimensions ............................................................................................ 17 

5.2.1 Study Area Dimensions ........................................................................................................... 18 

5.2.2 Eastern Corridor Dimensions ................................................................................................... 19 

5.3 Terrestrial Baseline Report Deficiencies ......................................................................................... 19 

5.3.1 Large Mammal Survey Deficiencies ........................................................................................ 20 

5.3.2 Small Mammal Trapping Deficiencies ..................................................................................... 24 

5.3.3 Bird Survey Deficiencies........................................................................................................... 25 

5.3.4 Vegetative Survey Deficiencies ................................................................................................ 28 

5.4 Aquatics Baseline Report Deficiencies ............................................................................................ 31 

5.5 Hydrology Baseline Report Deficiencies ......................................................................................... 34 

5.6 Habitat Fragmentation .................................................................................................................... 35 

5.7 Environmental Protection and Mitigation Plans ............................................................................. 35 

5.8 Cumulative Impacts Assessment and Residual Effects ................................................................... 36 

5.9 Future Corridor Upgrades ............................................................................................................... 37 

5.10 GCU and Domtar Synergies ............................................................................................................. 37 

5.11 Corridor Rehabilitation ................................................................................................................... 38 

5.12 GCU Preliminary Economic Assessment and Stock Volatility ......................................................... 40 

6 Summary of Recommendations ............................................................................................. 42 

3


March 30, 2013 

1 Overview 

Beginning in 2012, Gold Canyon Resources (GCU) put forward a proposal to develop a 

seasonal access road to their primary drilling exploration site at Springpole Lake. The road 

will extend roughly 43 Km northeast off the Wenasaga road from Ear Falls ON. After 

reviewing road alternatives, GCU decided to pursue a road through the eastern corridor, 

which requires clearing of roughly 645 km 2 of forested area. 

In 2011 GCU contracted DST Consulting Engineers to conduct general environmental 

baseline studies within the Springpole area. The general environmental baseline studies 

were used to develop future Environmental Study Reports (ESR) for various projects; 

eastern corridor development and increased mining exploration. 

In July 2012 GCU released their Springpole Exploration & Access Corridor Base Case 

Project Description Report, which was sent out to Stakeholders (tourist outfitters), First 

Nation communities and interested parties. In October 2012 GCU released the Springpole 

Gold Access Corridor Draft Environmental Study Report (ESR) to solicit feedback from 

Stakeholders, First Nation communities and interested parties. Numerous tourist outfitters 

raised objections to the project for reasons ranging from economic to environmental. 

In November 2012, four tourist outfitters; Kabeelo Lodge, Birch Lake Lodge, Northern 

Wilderness Outfitters and KayAir Service & Outposts (Trout Forest Tourist Outfitters), 

collaborated to seek legal counsel regarding unresolved socio-economic and environmental 

impacts resulting from eastern corridor development and operations. GCU did not provide 

adequate environmental mitigation measures, nor any feasible options to tourist outfitters 

for compensation due to economic loss incurred through loss of remote tourism value. 

On March 2, 2013 GCU submitted their Springpole Gold Access Corridor Project Final ESR 

under a Class C Environmental Assessment (EA), to the Ontario Ministry of Natural 

Resources (OMNR) for approval. Stakeholders, First Nation communities and interested 

parties received notification by email of the Final ESR from GCU, accompanied with an 

electronic copy of the Final ESR (no technical reports were submitted): the OMNR did not 

contact Stakeholders, First Nation communities or interested parties. 

This report is a review of the GCU Final ESR and Baseline Environmental Technical Reports 

(Technical Reports) submitted on March 2, 2013 to OMNR for approval by GCU, and 

highlights deficiencies encountered with the ESR, Technical Reports and Preliminary 

Economic Assessment, as reviewed by Trout Forest Tourist Outfitters. 

Stakeholders have been very clear to the OMNR and GCU, that continued exploration 

at Springpole does not require a winter road, and the rationale and baseline 

environmental studies used to justify the project are without merit. 

4


March 30, 2013 

1.1 Report Objectives 

1) To highlight the fact that GCU did not conduct the required baseline environmental 

studies from which the eastern corridor ESR was drafted, in order to gain OMNR 

approval for the project; 

2) That the project will have far reaching environmental impacts, and a more thorough 

environmental and socio-economic analysis is required prior to project approval. 

3) To request a Part II Order to elevate the Environmental Assessment requirements 

for this project from a Class C to a Class D. 

4) Require that GCU provide a Reclamation Bond with the OMNR to ensure that money 

is available for land rehabilitation. 

1.2 Stakeholders and First Nation Communities 

The Trout Forest area supports a variety of wilderness tourism operations, which promote 

northwestern Ontario and strive to maintain sustainable and environmentally conscious 

businesses. 

First Nation communities affected by Springpole exploration activities are Cat Lake First 

Nation, Slate Falls First Nation, Lac Seul First Nation and Wabauskang First Nation. Failure 

of GCU and the OMNR to recognize the traditional and Treaty lands impacted by GCU 

related Springpole activities, infringes upon Aboriginal and Treaty rights: Stakeholders 

support the interests and rights of local First Nation communities. 

Local tourist operators have a long established relationship with local First Nation 

communities, providing jobs and community support. Trout Forest tourism forms a strong 

component of local heritage and culture, which is evident in the Ear Falls and Red Lake 

communities, that work with and support local tourism. 

GCU conducted two “consultation” rounds with Stakeholders, First Nation communities, 

organizations and the public. Issues were raised about how GCU engaged with affected 

First Nation and non-First Nation parties, as there was little time between initial 

“consultation” and completion of the Draft ESR by GCU. 

5


March 30, 2013 

Table 1. List of Stakeholders, First Nation communities, organizations and interested 

parties, that GCU contacted throughout the spring and summer of 2012. 

Round One Consultation Round Two Consultation 

Tourist Outfitters: 

Pickeral Arm Camps 

KaBeelo Lodge 





True North Outposts and Camps 

Green Airways 

Bait fishermen: 

Best Baits 

Whitewing Floating Lodge 

D & E Minnows 

Bear Management Licenses: 

Green Airways 


Private Land Owners: 

Ruth Johnson 

Green Airways 




Douglas Bay Camp McKenzie John 

Ear Falls Contracting Ltd. Robinson Richard 

Ear Falls Hunters & Anglers Westcott Lloyd 

Ear Falls Trappers Council Lamond Lori 

Federation of Naturalists Estabrooks Gloria 

Hydro One Bowen John 

Ministry of Citizen, Culture, Tourism & Recreation Boulton 

James 

Ministry of Culture and Recreation Collins Brian 

Ministry of Labour Bartlett Daley 

Ministry of Northern Development & Mines Lichblau 

Andreas 

Ministry of the Environment Hoffmeister Matt 

Municipality of Red Lake Vinet Reeve Phil 

Native Trapper's Council Imbeault Ed 


North Lake Lodge Woolison Jerrold 

Northwest Metis Nation of Ontario Council Alvina Cimon 

President 

Northwestern Ontario Prospectors Assoc. Trelinski relinski 

Tomom 


Ontario Baitfish Association Bernier Ken 

Ontario Federation of Anglers & Hunters Pineo Robert 


Red Lake Trapper's Council Miron Benoit 

Township of Ear Falls Kahoot Mayor Kevin 


Windigo Tribal Council (represent Cat Lake and Slate Falls) 

Bimose Tribal Council (represent Wabauskang) 

Independent First Nation Alliance (represent Lac Seul) 

Aboriginal and Northern Development Canada (formerly 

INAC) 

Wildlands League Hesselink Trevor 

Greenpeace Brooks Richard 

Forest Ethics Grant Catherine 

Earthroots Armstrong Carly 

Ontario Natura Bell Anne 

6


March 30, 2013 

2 Springpole Eastern Corridor Conflicts 

2.1 Project Timeline 

Based on information extracted from various sections of the GCU ESR, Technical Reports 

and Stakeholder notes, below is the timeline during which submitted GCU road access 

reports and documents for review from 2012 – 2013. 

1. Springpole exploration and access corridor project: base case project description 

report, july 2012 

2. Springpole exploration and access corridor project: draft environmental study 

report (esr), october 2012 

3. GCU 2011 Baseline Study April 2012 

4. GCU 2011 Fisheries Baseline Study July 2012 

5. GCU 2011 Meteorology, Air Quality and Noise Baseline Study March 2012 

6. GCU 2011 Aquatic Baseline Study March 2012 

7. GCU 2011 Terrestrial Baseline Study April 2012 

8. GCU Preliminary Economic Assessment (PEA) March 26, 2013 

GCU began presenting information to Stakeholders, First Nation communities and 

interested parties during the spring of 2012. GCU presented on the economic benefit the 

project would provide for the community, and that there would be limited environmental 

impacts. At the time GCU began presenting to Stakeholders, First Nation communities 

and interested parties, the Draft ESR, Preliminary Economic Assessment and 

Baseline Environmental Technical Reports were not complete. 

GCU also failed to engage with First Nation communities prior to initiating desktop and 

field study work required for the Baseline Environmental Technical Reports. The Crown 

should have first notified and consulted with First Nation communities prior to GCU 

conducting any environmental work in the Springpole area. Failure to consult with First 

Nation communities infringes on traditional land use, Aboriginal and Treaty rights. 

What is evident from the timeline presented is that GCU wanted to expedite approval for 

the proposed eastern corridor and in their haste faile to 1) complete the required 

environmental and economic assessments prior to preparing an ESR and 2) properly 

engage with Stakeholders and First Nation communities potentially impacted by the 

project. 

2.2 Major Concerns Identified by Stakeholders 

After receiving the information from GCU on July 2012, regarding their intention to build 

an access road to the Springpole exploration property, concerned tourist outfitters in the 

area submitted letters of concern, objecting to the corridor development. 

7


March 30, 2013 

Issues identified by Stakeholders and Tourist Outfitters; 

Eastern corridor will have negative impacts on local tourism due to loss of remote 

value of the area; 

Creating new access to remote lakes; 

Increased noise and disturbance from road use and exploration activities; 

Destruction of viewscape at Birch River crossing; 

Establishment of a good neighbour policy; 

Damage to the environment, wildlife and water quality; 

Width of eastern corridor; 

Increased break-ins on property due to increased access to lakes; 

Habitat fragmentation and impacts to woodland caribou. 

Ultimately, Stakeholders are concerned that the eastern corridor project will 1) irreversibly 

jeopardize Trout Forest remoteness, which will permanently devalue Trout Forest tourism 

and 2) irreversibly destroy valued environmental landscape, wildlife habitat; woodland 

caribou and water quality. 

Issues brought forward by Stakeholders to GCU and OMNR received little attention, or no 

response at all. Comments were listed within the ESR (Table 3-2), however there was little 

follow-up on the part of GCU. 

Stakeholders have been very clear to the OMNR and GCU that continued exploration 

at Springpole does not require a winter road, and the rationale used to justify the 

project is without merit. 

Recommendation: GCU should not consider any issue identified by Stakeholders, First 

Nation communities, etc, as resolved until GCU receives confirmation in writing from the 

affected party that the issue is considered RESOLVED. 

8


March 30, 2013 

3 Federal and Provincial Policies 

Adherence to federal and provincial policies is required to ensure maximal protection and 

mitigation of potential socio-economic and environmental impacts or infringement of 

Aboriginal and Treaty rights. 

Throughout the ERS, continual mention is made by GCU of their being in the process of 

reviewing federal and provincial regulations specific for the project. This is of concern, 

given that a proponent applying for licensing should have reviewed and adhered to all 

federal and provincial regulations prior to the time of submission. 

GCU references meetings with Department of Fisheries and Oceans and ensuring that GCU 

is applying all the necessary measures required to mitigate against negative impact to fish 

habitat. However there is no discussion pertaining to what those mitigation measures are, 

nor that there will be consultation with affected tourist outfitters and First Nation 

communities (ESR, page 37). 

List of applicable acts referenced by GCU (GCU ESR, page 36): 

Navigable Waters Protection Act 

Federal Species At Risk Act – mammals and fish only 

Provincial Endangered Species Act – mammals and fish only 

Crown Forest Sustainability Act 

Public Lands Act 

Ontario Lakes and Rivers Improvement Act 

3.1 Ontario Lakes and Rivers Improvement Act 

The Lakes and Rivers Improvement Act has been referenced in the ESR, however there has 

been an oversite with its interpretation. Under part II of the Act: Public Rights in Lakes and 

Rivers, it stipulates that persons (proponents) shall not contaminate any water body. 

Lakes and Rivers Improvement Act, 1998, c. 18, Sched. I, s. 36. 

“Throwing matter into lake or river in conflict with purposes of Act 

36. (1) No person shall throw, deposit, discharge or permit the throwing, depositing or 

discharging of any substance or matter in a lake or river, whether or not the lake or river is 

covered by ice, or on the shores or banks of a lake or river under circumstances that conflict 

with the purposes of this Act. 1998, c. 18, Sched. I, s. 36; 2009, c. 33, Sched. 22, s. 5 (2).” 

“Order to remove 

(2) If any substance or matter is deposited, thrown or discharged in a lake or river or on the 

shore or banks of a lake or river in circumstances that the Minister considers conflict with the 

purposes of this Act, the Minister may order the person who did the act or caused it to be done 

to take such steps, within the time specified in the order, as the Minister considers necessary 

to remove the substance or matter from the lake or river or the shore or bank, as the case may 

be. 1998, c. 18, Sched. I, s. 36; 2009, c. 33, Sched. 22, s. 5 (2).” 

http://www.e-laws.gov.on.ca/html/statutes/english/elaws_statutes_90l03_e.htm#BK31 

9


March 30, 2013 

Within the Aquatics baseline Report, it has been identified that there is a dramatic 

elevation in heavy metals in Springpole compared to what is approved in Provincial 

Water Quality Objectives (PWQO) (Section 4.4). GCU has been conducting 

exploratory drilling in Springpole for many years, which strongly supports the 

possibility that GCU drilling activities are polluting Springpole. 

If GCU activities are found to increase the heavy metal content in Springpole and 

surrounding lakes, they will be in direct violation of the Lakes and Rivers Improvement Act. 

Relevant Acts that are missing from GCU ESR but are not limited to: 

Ontario Water Resources Act 

Ontario Heritage Act 

Expropriations Act 

Ontario Road Access Act 

Federal Species At Risk Act – vascular plants and mosses 

Ontario Endangered Species Act – vascular plants and mosses 

3.2 Ontario Water Resources Act 

As previously discussed within the Lakes and Rivers Improvement Act, there is a 

responsibility of the proponent to ensure that lakes and rivers are not contaminated by 

their activities. In addition to that, given that Springpole and surrounding lakes provide 

drinking water tourist operations and private land-owners, there is an additional 

requirement that the pristine lakes are kept free of contaminants. Given the Preliminary 

Economic Assessment (PEA) was completed after the ESR submission by GCU, there is no 

discussion of how such matters as “dike construction”, “dewatering” and “open pit 

development” will be addressed within the context of existing water regulations. 

Ontario Water Resources Act: Water, 2011, c. 9, Sched. 27, s. 36 

“Purpose 

0.1 The purpose of this Act is to provide for the conservation, protection and 

management of Ontario’s waters and for their efficient and sustainable use, in order to 

promote Ontario’s long-term environmental, social and economic well-being. 2007, c. 12, 

s. 1 (1).” 

“Examination for pollution 

(2) The Minister may examine any surface waters or ground waters in Ontario from 

time to time to determine what, if any, pollution exists and the causes thereof. R.S.O. 1990, 

c. O.40, s. 29 (2).” 

“Injunction to prevent pollution of water 

(3) Where any person is discharging or causing or permitting the discharge of any 

material of any kind into or in or near any waters that, in the opinion of the Minister, may 

impair the quality of the water in such waters, the Minister may apply without notice to the 

Superior Court of Justice for an order prohibiting such discharge for such period not 

exceeding twenty-one days and on such terms and conditions as a judge considers proper, and 

such order may, on application to the Court, be continued for such period and on such terms 

10


March 30, 2013 

and conditions as a judge considers proper. R.S.O. 1990, c. O.40, s. 29 (3); 2001, c. 9, Sched. G, 

s. 6 (50).” 

“Discharge of polluting material prohibited 

30. (1) Every person that discharges or causes or permits the discharge of any 

material of any kind into or in any waters or on any shore or bank thereof or into or in any 

place that may impair the quality of the water of any waters is guilty of an offence. R.S.O. 

1990, c. O.40, s. 30 (1).” 

“Ministry to be notified when polluting material is discharged or escapes 

(2) Every person that discharges or causes or permits the discharge of any material of 

any kind, and such discharge is not in the normal course of events, or from whose control 

material of any kind escapes into or in any waters or on any shore or bank thereof or into or 

in any place that may impair the quality of the water of any waters, shall forthwith notify the 

Ministry of the discharge or escape, as the case may be. R.S.O. 1990, c. O.40, s. 30 (2); 2006, 

c. 19, Sched. K, s. 3 (2).” 

http://www.e-laws.gov.on.ca/html/statutes/english/elaws_statutes_90o40_e.htm#BK47 

3.3 Ontario Heritage Act 

The Ontario Heritage Act is designed to help protect heritage properties and archaeological 

sites. Under the Act, there are provisions to protect areas of historic, architectural 

archaeological, recreational, aesthetic, natural and scenic interest. 

Springpole and surrounding areas are of archaeological, recreational, aesthetic, natural and 

scenic interest to local stakeholders and First Nation communities. Hence provisions under 

the Ontario Heritage Act, should be issued to protect the valued sites located in Springpole 

and surrounding areas. Below is the excerpt from the Ontario Heritage Act confirming the 

above statement; 

Ontario Heritage Act: Part II – Ontario Heritage Trust, 2009, c. 33, Sched. 11, s. 6. 

7. The objects of the Trust are, 

(a) to advise and make recommendations to the Minister on any matter relating to 

the conservation, protection and preservation of the heritage of Ontario; 

(b) to receive, acquire and hold property in trust for the people of Ontario; 

(c) to support, encourage and facilitate the conservation, protection and 

preservation of the heritage of Ontario; 

(d) to preserve, maintain, reconstruct, restore and manage property of 

historical, architectural, archaeological, recreational, aesthetic, natural 

and scenic interest; 

(e) to conduct research, educational and communications programs necessary for 

heritage conservation, protection and preservation. R.S.O. 1990, c. O.18, s. 7; 

2005, c. 6, ss. 1, 5. 

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March 30, 2013 

http://www.e-laws.gov.on.ca/html/statutes/english/elaws_statutes_90o18_e.htm 

The Springpole and surrounding areas belong to the traditional lands of many First 

Nation communities including; Cat Lake, Slate Falls, Lac Seul and Wabaskang First 

Nations. The area also belongs to Treaty 3 of which Cat Lake and Slate Falls First 

Nations are signatory to. Archaeological studies conducted by GCU has identified two 

locations near areas of cultural significance to First Nation communities; Birch River 

crossing and south of Dole Lake. Given that GCU has not provided any Archaeological 

Technical Report for stakeholders to review, and it is stated repeatedly throughout the ESR 

that more archaeological studies are required, it is logical to conclude that the 

archaeological study is incomplete and grossly underestimates the heritage value of the 

region. 

http://www.e-laws.gov.on.ca/html/statutes/english/elaws_statutes_90e26_e.htm#BK6 

Note: In addition to the water quality issues discussed in the ESR it should be noted 

that no where does GCU identify or address water quality issues regarding the 

construction phase of the eastern corridor project. Furthermore, GCU does not 

reference water quality issues pertaining to Springpole exploration related activities 

such as dike construction, dewatering or open pit development all of which are 

suggested in the March 25, 2013 preliminary economic assessment. 

Recommendation: GCU needs to fully disclose ALL potential water related activities 

associated with eastern corridor development or Springpole exploration. Once identified, 

GCU needs to further outline all water quality issues potentially resulting from those 

projects/activities, without drawing bias conclusions regarding their “significance”. 

Recommendation: GCU needs to provide a preliminary rehabilitation and closure plan, 

that specifically addresses costs associated with all water related activities and 

contamination, both locally and downstream. 

Recommendation: GCU needs to conduct a down-stream and long-term water quality 

impacts assessment, that investigates local and regional impacts to surface and ground 

water quality, changes to hydrology, impacts to terrestrial and aquatic wildlife, impacts to 

local tourism and impacts First Nation traditional land use and Treaty rights. 

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March 30, 2013 

4 Class Environmental Assessment & Unresolved Environmental Issues 

The rationale for identifying the GCU road project as Class C rather than a Class D 

undertaking, is not clear, as there are far reaching impacts of this road proposal that have 

yet to be addressed. 

As previously discussed, GCU intends to clear 645 km 2 of land for corridor use: A fact 

that was not clearly identified within the ESR. The environmental impact assessment 

conducted, was not specific for the road project, and failed to assess any areas close to 

where the road is proposed. Given that 645 km 2 of land is to be cleared, it is imperative 

that a full environmental assessment be conducted for the specified project and areas of 

impact. 

Table 2: Considerations for Class C vs Class D Environmental Assessment (OMNR Resource 

Stewardship & Facility Development Projects, page 26). 

Class C considerations 

Class D considerations 

 

 

 

 

 

 

Medium to high potential for significant net 

negative effects 

There is some uncertainty associated with 

predictions of effects, requiring additional 

research and/or evaluation 

The appropriate type of management 

direction is in place for the project, but it does 

not fully define the project, or the plan 

suggests that alternatives should be 

considered or additional evaluation carried 

out 

If a project is proposed when the appropriate 

type of management direction is not in place 

(see Section 2) 





alternatives 

 

 

 

 

 

 

Several inter-related aspects that have high 

potential for either net positive or negative 

environmental effects that may conflict, 

suggesting a complex situation 

Potential for serious negative effects on 

species at risk 





other alternatives 

Involves a new or contentious interpretation 

of management direction or other MNR policy 

A distinct benefit can be derived from the 

process requirements of Part II of the EA Act, 

including Terms of Reference, formal 

government review and a decision by the 

Minister of the Environment (or the 

Environmental Review Tribunal) 

There are many environmental issues specific for construction, operation and maintenance 

of a corridor which need to be addressed. In this instance there are a variety of 

compounding factors, which require a more thorough examination of the socio-economic 

and environmental implications of this project; 

The corridor will traverse through and fragment endangered woodland caribou 

habitat; 

Increased predation and hunting will occur in the area as a result of the corridor, and 

increase hunting and predation pressure on moose, woodland caribou, large 

furbearers, etc; 

Eastern corridor will destroy 645 km 2 of old growth boreal forest; 

Impacts to water quality through increased sedimentation Birch River crossing; 

Impacts to critical fish spawning habitat at Birch River crossing; 

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March 30, 2013 

 

 

 

 

 

Increased all season access to pristine lakes which will increase fishing and hunting 

pressures in the area; 

Loss of remote tourism business for local tourist outfitters; 

Noise and light disturbance to wildlife; 

Increased number of wildlife vehicle strikes; 

Infringement on First Nation Aboriginal and Treaty rights. 

Due to yet unresolved environmental and socio-economic impacts that the proposed 

eastern corridor will cause, this project requires an independent environmental 

assessment under a Class D EA. 

A part II order is being requested, in order to facilitate the required environmental 

assessment for the project. 

Recommendation: That the OMNR issue a PART II ORDER and require GCU to complete a 

separate Class D Environmental Assessment for the eastern corridor project. 

4.1 Good Neighbour Policy 

The development and implementation of a “Good Neighbour Policy” by GCU was referenced 

within the ESR (Table 3-2, page 31). No follow-up actions by GCU have been pursued to 

develop and implement this document, which would help mitigate some concerns raised by 

stakeholders. 

If the eastern corridor is to proceed, the “Good Neighbour Policy” needs to be developed in 

conjunction with stakeholders, and uphold all the principles laid out within. There is 

currently no indication of when the document will be completed, who will draft it and how 

it will be upheld. 

The Good Neighbour Policy requires the following but is not limited to; 

Be referenced in all future GCU related documentation pertaining to Springpole 

exploration, including within all permits issued by OMNR; 

Outline a communications strategy between Stakeholders, GCU and OMNR; 

Outline compliance measures; 

Account for socio-economic and environmental issues raised by Stakeholders; 

Outline compensation and accommodation measures for Stakeholders in the event of 

economic loss due to GCU related activities; 

Outline reporting schedule for environmental monitoring studies from GCU to 

Stakeholders; 

Have a single document containing all guidelines and activities for environmental 

monitoring schedules, methodology, analysis, reporting, etc; 

Outline decommissioning process of the eastern corridor; 

How to address continued concerns raised by Stakeholders, First Nation 

communities and interested parties. 

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March 30, 2013 

Recommendation: That GCU develop and implement a “Good Neighbour Policy”, in 

conjunction with Stakeholders, prior to approval of the eastern corridor project. 

Recommendation: The “Good Neighbour Policy” should stay in effect for the duration of 

Springpole exploration activities, independent of GCU ownership. 

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March 30, 2013 

5 ESR and Technical Report Deficiencies 

This review of the ESR is done so, with the intention of identifying study deficiencies and 

gaps in the methodologies used to assess wildlife, eco-sites, archeological sites, soils and 

terrain, vegetation, ground water, cumulative and socio-economic impacts, etc. 

In general the ESR is lacking in technical detail to explain methodologies, data 

interpretation, and statistical analysis of results. Review of the supporting Baseline 

Technical Reports reveals a variety of study deficiencies in the areas of; study 

methodology, types of studies performed, insufficient data collection, irrelevant data 

presentation, statistical analysis and missing data. 

Aside from overall study deficiency, the studies themselves were not conducted in 

locations relevant to assess the socio-economic or environmental impacts of the 

eastern corridor. 

GCU did not adequately engage First Nation communities while conducting the 

baseline study fieldwork and desktop analysis for; terrestrial, aquatic, hydrological, 

meteorological, baseline studies. First Nation communities understand the land and 

can contribute valued traditional knowledge. Hiring one or two First Nation 

individuals does not constitute 1) proper engagement with First Nation 

communities, and 2) utilizing traditional knowledge to ensure protection of the 

environment and traditional land use, Aboriginal and Treaty rights. 

Flawed baseline environmental studies imply that the ESR findings, which are based 

on the environmental studies, are also flawed and incomplete. 

Recommendation: GCU needs to conduct thorough environmental baseline studies in 

conjunction with First Nation communities, and jointly engage with those communities 

throughout the planning, hiring, implementation, analysis and report writing stages of all 

studies. 

5.1 Project Rationale 

Within ESR section 1.3: Purpose and Justification for Project, GCU describes how the 

Springpole Gold Project, not to be confused with the eastern corridor project, will benefit 

the local economy. GCU makes statements that the Springpole Gold Project will lead to 

increased jobs (>500), local manufacturing, increased tax revenue, etc. 

This is all well and good, except for the fact that the economic assessment was not 

completed and published online until March 25, 2013. Therefore the statements made 

within the ESR, released March 2, 2013, regarding project economic benefit are unfounded. 

Furthermore, the ESR submitted is for the eastern corridor, and not the Springpole gold 

project: two very different things. Inclusion of information not directly related to the 

eastern corridor, should be removed from this ESR, as it seeks to convince the reader that 

16


March 30, 2013 

there is more economic benefit to the eastern corridor project, without the evidence; 

economic assessment, to back it up. 

The eastern corridor is not necessary for continued exploration at Springpole by 

GCU, and is being perused to increase Springpole property and GCU stock value. 

In past it was clearly communicated by GCU and MNR that stakeholders (tourist outfitters) 

could only raise concerns pertinent to corridor development, and any reference made to 

exploration activities and their impacts were not entertained. Therefore, in future if GCU is 

to make reference to exploration activities within the ESR, as a means of justifying road 

construction activities, then concerned stakeholders should have the right to comment and 

raise concerns about the full extent of GCU Springpole Gold Project activities. 

Recommendation: GCU needs to remove all reference to Springpole exploration as a 

justification for development of the eastern corridor. If reference is not removed, then 

Stakeholders, First Nation communities, organizations and the public will freely comment 

on all aspects of GCU Springpole related activities as a whole. 

5.2 Study Areas and Corridor Dimensions 

What is not discussed throughout the ESR and Technical Reports, is the total length and 

dimensions of the proposed eastern corridor, nor the exact areas investigated during the 

baseline fieldwork studies. 

In typical ESRs pertaining to roadways or access corridors, there is a full description of the 

length, width and potential impact zone of the corridor, as well as project area description. 

With typical corridor projects, a surrounding impact/buffer zone is established, based on 

the anticipated environmental and socio-economic impacts the project will have. GCU did 

not stipulate in the ESR or Technical Reports that a impact/buffer zone had been 

established. The rationale behind establishing an impact/buffer zone is to mitigate 

potential negative impacts associated with corridor use that may be inflicted upon nearby 

water bodies, land occupants, First Nation traditional use activities, archaeological sites, 

wildlife, protected areas, etc. 

As it pertains to safety, which is a justification for the project, road dimensions should be 

clearly stated. Those who travel along the Wenasaga Road, will notice numerous grave sites 

located along the ditches. GCU does not provide any safety statistics for travel on the 

Wenasaga road. Portions of the Wenasaga road are used by private land-owners, increased 

large truck traffic on that road will inevitably lead to an increased number of collisions and 

wildlife strikes: Which will be compounded if Domtar also uses the same corridor. 

Recommendation: GCU and OMNR need to publish the all-season road safety statistics for 

the Wenasaga road, and include preliminary calculations based on statistics, on what future 

road safety projections might be. 

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March 30, 2013 

Recommendation: The OMNR needs to investigate the safety of the Wenasaga road, and 

determine the large truck allowance for the seasonal corridor. 

5.2.1 Study Area Dimensions 

The below terminology is used throughout the GCU ESR and Technical Reports to describe 

the areas in which field work or desk-top surveys were conducted. For each Technical 

Report, and depending on what was being assessed, study area dimensions differ. Despite 

the fact that there are varied study areas, the same terminology is used throughout all ESR 

documents to describe these areas. 

The maps provided by GCU to depict where the study areas are located are of poor quality 

and have low resolution, limiting ones ability to actually read any land base descriptions. 

Study Area Terminology Used: 

Regional study area 

Local study area 

Study site 

Springpole study area - general 

Throughout the ESR and Technical Reports there is one reference to the actual amount of 

land surveyed for wildlife: It was stated that 81 km 2 was surveyed during the aerial wildlife 

fieldwork study (Draft Springpole Terrestrial Baseline Report 2011 

What is not discussed are the specific land quantums for any of the above listed “study 

areas”, nor rationale to justify/explain the why the area and amount of land was selected. 

In most cases, the field study work was conducted in overlapping locations within 1km of 

the primary Springpole camp site, a location which the drills operate 24 hours a day. 

After review of the study areas used by GCU, it appears as though only small local 

study areas were selected from within the Springpole study area in order to dilute 

the impact of potential findings to make them appear insignificant. 

Furthermore, the location of all the local study areas used to for the baseline studies, 

are located nowhere near the intended corridor. 

Recommendation: GCU needs to explicitly define each study area used within all baseline 

technical reports for which fieldwork and desktop analysis was conducted in, and indicate 

within the ESR where exactly the baseline studies were conducted in relation to the eastern 

corridor. 

Recommendation: GCU needs to conduct a Class D Environmental Assessment specific for 

the eastern corridor. 

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March 30, 2013 

5.2.2 Eastern Corridor Dimensions 

Throughout the ESR there is little discussion of the actual dimensions to be used for the 

anticipated corridor. There is reference to the road having dimensions appropriate for a 

forestry road, however they are not specified. 

Only after requesting the information from GCU, did they indicate that the corridor would 

be 15 m wide by 43 km in length, equalling 645 km 2 in total area to be cleared. It was 

not stated within the ESR nor Technical Reports, on the true extent of land to be cleared by 

GCU for the corridor. 

It was stated that a 500 m buffer zone was used to determine corridor impact to large 

furbearers; woodland caribou, however it is not clear if this same buffer zone was applied 

for other wildlife calculations. 

Recommendation: GCU needs to clearly identify eastern corridor dimensions in all GCU 

eastern corridor related documents, stating that 645 km 2 of land needs to be cleared for the 

project. 

Recommendation: GCU needs to provide an explanation for how the impact/buffer zone 

area was determined. 

5.3 Terrestrial Baseline Report Deficiencies 

The terrestrial baseline studies conducted were intended to assess a limited area within 

the broader Springpole study area, and do not reflect the true environmental conditions. 

Baseline studies are designed to establish what environmental parameters currently exist 

in the area, without industrial pressure, so as to determine the degree of impact that the 

intended industrial activity will introduce. 

The bulk of terrestrial baseline field-work studies were conducted within roughly a 3 km 

radius of the primary Springpole campsite. The primary Springpole campsite is an area of 

high anthropogenic activity and noise, causing it to be a site of environmental disturbance. 

Conducting baseline environmental assessments for wildlife in an area with noisy 

industrial activity, would predisposed the study to finding little wildlife in the area: 

at the outset of the studies, there is already experimental bias introduced. 

The methodology employed for all studies lacks scientific significance and statistical 

analysis: many were only conducted only once, and in an area not reflective of the eastern 

corridor. Therefore, the ESR is misleading in presenting that there will be minimal impact 

to wildlife, as the baseline studies were biased, and fraught with defects as highlighted in 

the corresponding sections below. 

In some instances, the desktop analysis conducted for the entirety of the regional 

project study area, used outdated database information. 

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March 30, 2013 

Aside from using flawed fieldwork methodology to assess terrestrial baseline parameters, 

the study did not take into consideration amphibians, reptiles, mosses and insects. The 

below table summarizes field study information, highlighting how little fieldwork was 

actually conducted: estimate 6.5 days for total terrestrial fieldwork . For all terrestrial 

baseline studies no statistical analysis was conducted, and in most cases only a single 

sampling was collected through fieldwork. 

Table 2. GCU Terrestrial Baseline Study Report fieldwork dates and duration of data 

collection. 

Technical Report Date Area Type Duration 

Terrestrial 

- Lg. Mammals 

- 

- Sm. Mammals 

Feb 5, 2011 

June 23 & 24, 

2011 

81 km 2 

8 days 

The ESR made the following statement regarding environmental affects resulting from the 

eastern corridor: “Based on the information provided in this report and taking into account 

the proposed mitigation measures, the proposed project is not likely to result in any 

significant adverse environmental effects on the terrestrial environment (ESR page 3-2).” 

5.3.1 Large Mammal Survey Deficiencies 

The large mammal survey was conducted to determine baseline levels of moose, woodland 

caribou, wolverine and other large mammals in the Springpole study area. The study was 

conducted over 81 km 2 on February 5, 2011, through a single aerial survey at 300 m above 

ground. 

The aerial survey was conducted in a region that was non-specific for the intended eastern 

corridor, and focused on lands immediately around the western, northern and upper east 

portions of Springpole Lake. For the large mammal survey there is little empirical evidence 

used to draw study conclusions and conduct statistical analysis of findings. 

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March 30, 2013 

5.3.1.1 Moose 

Road access to the project site has “… potential adverse effects … with habitat loss, general 

disturbance, and hunting mortality…”. 

By use of OLT modeling the study concluded that predicted moose densities are considered 

to be low” in the Springpole project area. To further substantiate this position, on February 

5, 2011, the consultant conducted an aerial moose survey in the Springpole project area 

and reported the “sighting of 6 cows and 2 calves, no bulls, no ticks…”. 

Furthermore, GCU acknowledges the project road corridor may lead to potentially greater 

hunting mortalities among moose populations due to more hunting opportunities. The use 

of modeling and aerial surveys in this instance may provide useful information to GCU but 

has lead to erroneous conclusions. 

Empirical data and over thirty years of outfitter presence in the Springpole can ascertain 

that: a) moose populations are healthy in WMU 16A; b) non-resident hunter moose success 

rates for the past 30 plus years has averaged between 60-65%; c) First Nation hunting 

derbies in the Birch Lake/Springpole complex have been highly successful; d) resident 

moose hunters continue application to hunt the area due to large moose populations; and, 

e) floatplane pilots on their daily flight patterns consistently report significant sightings of 

bull, cow and calf moose. 

The conclusion to be drawn: the methodology utilized by GCU was flawed and lead to a 

series of incorrect conclusions. In point of fact, road access to the Springpole Project site 

will have major environmental impacts for the moose populations through the loss of 

habitat, cause general and specific area disturbances and lead to greater animal mortality. 

Flawed study methodology; 

An area map should have been developed in conjunction with First Nations, OMNR 

and stakeholders to determine study boundaries; 

A grid of the study area should have been developed to determine potential areas of 

high and low moose populations; 

Numerous aerial surveys should have been conducted over the determined grid, 

occurring at different times of the year to account for seasonal variation; 

Calving or feeding areas should have also been identified; 

No data or discussion provided on current moose populations in the area; 

No data or discussion provided on moose range; 

No data or discussion provided on potential for increased predation and hunting due 

to eastern corridor; 

Little to no First Nation involvement. 

Recommendation: GCU in conjunction with First Nation communities, needs to conduct a 

thorough moose population study relevant to the eastern corridor, complete with fieldwork, 

statistical analysis and up to date desk-top analysis. 

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March 30, 2013 

Recommendation: Future desktop analysis of moose by GCU must include current data, 

and if the data is not available, GCU must clearly state that it is lacking. 

5.3.1.2 Woodland Caribou 

Woodland Caribou are listed as a “threatened species” both provincially and federally. 

Related to their threatened status is the fact that linear corridors (i.e. Springpole Access 

Corridor Project) have an adverse effect on caribou populations primarily through the 

introduction of easy access points for predatory animals such as bears and wolves. 

To date across Ontario it is estimated that woodland caribou habitat has decreased by 40- 

50% compared to the 1800’s, due to human related industrial activity. Woodland caribou 

have adapted to disturbance by wildfire, however the additional disturbance of human 

activity is an added stress and functionally different than wildfires. 

The key concerns for caribou “protection” rests with adherence to the minimization of the 

“anthropogenic … footprint”, “minimization of habitat loss”, “management of habitat 

arrangement and connectivity”, minimization of density of linear features”, mimimize 

“distribution and productivity of … prey species” and avoid “high use and calving sites…” 

These are the observations reported in the Biological Contraints [sic] Report September 

2012. 

All of the observations and attendant conclusions appear to result from literature 

reviews and/or model projections without the benefit of on-site observations or 

accumulation of empirical data. It does appear this operating model of “armchair 

analysis” will somehow lead to irrefutable observations thereby rendering the 

conclusions as valid. Given the literature survey did not yield any empirical data 

about the woodland caribou, and the potentially negative effects of the access 

corridor, it is quite clear that any and all environmental factors impacting the 

ecology of the woodland caribou must be placed front and center with additional 

studies and surveys prior to the granting of any permit to construct an access 

corridor to the Springpole project site. 

A review of Table 3.4.7 Comparison of road corridor options in the Springpole Lake area with 

regard to environmental effects to caribou clearly shows that both road options will have a 

negative effect on the Woodland Caribou. The Woodland Caribou is a threatened species 

and the granting of a harvesting permit, prematurely, will only serve to push this animal 

into the extinct category. The study concludes “… the potential impacts from habitat loss, 

fragmentation and disturbance can be considered to be negative …”. With permitting of the 

construction of the Springpole Access Corridor it is clear the life of the Woodland Caribou 

will be shortened and shortened dramatically. 

Disturbance statistics for woodland caribou were derived from the Cumulative Effects 

Assessment and Proposal Screening Report (CST-EOI-2012-0801-19/20) of the Churchill 

Caribou Range, produced by the OMNR. This report was not made available with the ESR, 

22


March 30, 2013 

and there was no background information provided regarding report interpretation or date 

of publication. 

The baseline study for woodland caribou consisted of a single aerial survey 

conducted on February 5, 2011 and database analysis from sources that were out of 

date and had no data available; 

Aerial survey was not conducted over known woodland caribou wintering, calving or 

refuge areas; 

Aerial survey was not conducted over an area relevant for the eastern corridor 

project; 

Database analysis for woodland caribou was referenced as having little to no 

available data for the study area. 

A thorough woodland caribou study needs to be conducted which takes into account 

the following parameters, relevant to eastern corridor development; 

Churchill woodland caribou herd numbers; 

Caribou herd range of occupancy; calving, refuge wintering areas, etc; 

Range disturbance by eastern corridor; 

Impact on food source; 

Degree of habitat fragmentation resulting from eastern corridor; 

Increased predation, hunting and vehicle kills; 

Cumulative impacts assessment on caribou; forestry, hunting, predation; 

First Nation involvement and traditional knowledge. 

The ESR and Technical Report state that insufficient data was available on woodland 

caribou to make any conclusions about the herd. Therefore, no conclusions 

regarding woodland caribou can be drawn from this study, and impacts to woodland 

caribou resulting from the eastern corridor cannot be regarded as insignificant. 


the OMNR needs to undertake a thorough environmental assessment of woodland caribou 


Recommendation: Future desktop analysis of woodland caribou by GCU must include 

current data, and if the data is not available, GCU must clearly state that it is lacking. 

5.3.1.3 Large mammals and furbearers 

Large mammals and furbearers were also assessed using the February 5, 2011 aerial 

survey. No additional follow-up studies were conducted. Empirical data on large mammals 

and furbearers (i.e. gray wolves, black bears, marten, lynx, beaver, muskrat, river otters, 

red fox, fisher) is absent from any reports generated by GCU. 

In the absence of data it is nearly impossible to draw any substantive conclusions about the 

environmental impacts to the flora and fauna in the Trout Forest and, hence, impossible to 

offer any mitigation measures to offset these environmental impacts. Nevertheless, GCU 

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March 30, 2013 

offers “principle mitigation measure designed to reduce the potential adverse effects to 

large mammals and furbearers … to restore the linear corridor and harvested patent 

land to productive wildlife habitat upon closure.” [Emphasis by this writer]. 

GCU will make the “ecology good” in the neighbourhood of twenty years!!! During this time 

period all large mammals and furbearers face a potential reduction in their numbers if not 

in their existence. 


the OMNR needs to undertake a thorough environmental assessment of large mammals 

and furbearers within the regional project study area, utilizing areas relevant to the eastern 

corridor. 

5.3.2 Small Mammal Trapping Deficiencies 

The small mammal survey was conducted by setting up 35 traps over an area less than 


March 30, 2013 


the OMNR needs to undertake a thorough environmental assessment of small mammals 


5.3.3 Bird Survey Deficiencies 

The avian study outlines how fieldwork and preliminary desktop studies were conducted. 

The fieldwork consisted of a breeding bird survey (BBS) and a whip-poor-will survey 

(WPWS). 

For the BBS and WPWS, there are a number of research methodology deficiencies 

identified. Common to both studies, there is no indication within the Terrestrial Baseline 

Study Technical Report of the actual study area dimensions used and justification for their 

selection, aside from what is depicted on the map provided (Figure 3.3: Point Count and 

Song Meter Locations in the Springpole Study Area (2011)). GCU has indicated that survey 

sites were randomly selected, however the bulk of the BBS and WPWS seem to fall in the 

exact same region as all the other terrestrial baseline studies, thereby negating 

randomness. 

Background research for the bird surveys was conducted using desktop analysis of the 

Natural Heritage Information Centre (NHIC) and Ontario Breeding Bird Atlas (OBBA) 

specific for Big Trout Lake. NHIC information was only up to date until 1999 and the OBBA 

information was current up to 2005 and for Big Trout Lake and overlapped with 15WS48, 

15WS49, 15WS58, and 15WS59 of the Springpole “regional study area”. The map 

provided by GCU for the bird surveys did not indicate where 15WS48, 15WS49, 

15WS58, and 15WS59 were located on the map. The technical report clearly states 

that there was no information available from that source for locations 15WS48, 

15WS49, 15WS58, and 15WS59: 



such, there were no associated bird observations (Terrestrial Baseline Report 2011, 

page 3-6).” 

In essence, the desktop research used to corroborate the fieldwork findings are incomplete 

and not relevant for the study in questionable, and cannot be used as a reputable source 

from which to draw conclusions about bird populations in the area. It was not discussed 

within the “Background Research” portion of the technical report (where the NHIC and 

OBBA were referenced) that the desktop analysis was out of date, and not specific for the 

area in question. 

Example of how outdated and misleading the NHIC and OBBA information is: “Bald eagles 

have been reported to the NHIC as having been in the area 4 times between 1990 and 1999 

(Draft Springpole Terrestrial Baseline Report 2011, page 3-4).” Not only is the reference 

outdated by14 years, bald eagles are common in the Birch Lake and Springpole areas. 

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March 30, 2013 

It should be noted, that database information used to assess the wildlife content of 

the area is out of date, and does not reflect actual species abundance. In essence, 

there is very little empirical data on birds used within the technical report. 

5.3.3.1 Breeding Bird Survey (BBS) Methodology Deficiencies 

This survey was conducted through a single session of 10, 10-minute interval non-fixed 

radial observation periods, equating to 100-minutes of observation time. The technical 

report references the fact that two separate radial observation sessions should have been 

conducted, and only one was conducted due to the 2011 forest fire, and there was no 

follow-up. 

There were two general observation locations from which the study was conducted, having 

a total of 11 observation sites; 8 within 2 km of the primary Springpole campsite and 3 

roughly 36 km southeast of campsite. Only the 3 sites selected that are away from the 

campsite, are near to where the intended road corridor will be implemented. The overall 

methodology used to conduct the breeding bird survey was not written in the technical 

report, only a reference was given for a paper by Konze and McLaren, written in 1997. 

According to Environment Canada: Breeding Bird Survey Statistical Methods, BBS routes 

are generally 24.5 km in length and consist of 50 three minute stops, spaced 0.8 km apart. 

The total number of birds seen or hear within 400 m are recorded. From what was 

described in the technical report, this methodology was not employed. 

Recommendation: GCU should conduct a thorough assessment of birds present in the 

regional study area, ensuring that adequate field-work is performed to overcome the lack 

of current database information. 

Recommendation: When GCU conducts their next bird survey, every effort should be 

made to gather sufficient data in accordance with tested methodologies, that allows for 

statistical analysis. 

5.3.3.2 Whip Poor Will Survey (WPWS) Methodology Deficiencies 

The methodology for this survey involved setting up automated birdcall recording stations, 

which were setup to record for ten minute intervals, every hour between 8:30 pm and 5:30 

am. The two recording stations were located on GCU patented claim area, located less than 

200 m apart and no more than 600 m from the primary Springpole campsite. The WPWS 

was conducted only once on June 17, 2011, and no action was taken to complete the 

second recording session. 

The Whip-poor-will is a threatened species due to habitat loss and fragmentation. 

Currently the OMNR is in the process of developing a species-specific habitat 

regulation and recovery strategy for this species (OMNR: Whip-poor-will, 2009). 

The methodology employed draws into question the validity of findings given that; 

The stations were located close to the primary camp in which there is already a high 

degree of industrial disturbance and noise; 

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March 30, 2013 

 

 

 

 

 

The stations are located close to one another, and there would be a high potential of 

overlap and duplication of observations; 

No stations were located near to where the intended road is planned; 

No stations were located near to other breeding bird survey observation sites 

located roughly 36 km away from the primary Springpole campsite; 

The study was only conducted once, with limited data points; 


Recommendation: If the OMNR is in the process of establishing a whip-poor-will specific 

habitat regulation and recovery strategy, GCU should be required to properly conduct a 

whip-poor-will species abundance study and cumulative impacts assessment, gathering 

sufficient information to conduct statistical analysis. 

5.3.3.3 Technical Report Bird Survey Findings 

“an active Bonaparte’s Gull (Larus philadelphia) nesting colony was found at one of the 

point count locations (Figure 3.3). The OMNR considers the nesting colonies of all bird 

species to be significant wildlife habitat (OMNR 2009), and as such they have a list of 

recommended guidelines to follow regarding these features (such as minimum buffer 

distances for disturbance and timing restrictions for construction activities) (Draft 

Springpole Terrestrial Baseline Report 2011, page 3-4).” 

“In addition to those species listed on the NHIC database, the OMNR’s Species at Risk website 

indicated a number of species that have the potential to occur within the study area 

including:black tern (Chlidonias niger – Special Concern), Canada warbler (Wilsonia 

canadensis – Special Concern), Common nighthawk (Chordeiles minor – Special Concern), 

Horned grebe(Podiceps auritus – Special Concern), Monarch butterfly (Danaus plexippus – 

Special Concern), Olive sided fly catcher (Contopus cooperi – Special Concern), Short-eared 

owl (Asio flammeus – Special Concern), and Yellow rail (Coturnicops noveboracensis – Special 

Concern). None of these species were encountered during any field work completed in 

2011 (Draft Springpole Terrestrial Baseline Report 2011, page 3-13).” 



such, there were no associated bird observations (Draft Springpole Terrestrial 

Baseline Report 2011, page 3-6).” 

“The principle potential adverse effects of the Project on migratory birds would be those 


nesting birds during the nesting season (April 1st to August15th) is also a concern. Table 3.2.1 


option and for the harvested patent land area (Draft ESR, page 3-6).” 

“Avian species richness was found to be relatively low within the RSA, which is typical of 

northern boreal forest sites (Draft ESR, page 2-4).” 

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March 30, 2013 

It should be noted, that in cases where there is little to no baseline data, that does not 

indicate that species in that area do not exist, it just means that the data has not been 

gathered yet. 

Given the identified deficiencies with the bird survey methodologies, the findings of 

the Terrestrial Baseline Report 2011 for birds are inconclusive, and cannot be used 

to arrive at the assumption that the project will not impact birds. 

Recommendation: GCU in conjunction with First Nation communities and the OMNR 

needs to undertake a thorough environmental assessment of birds within the regional 

project study area, utilizing areas relevant to the eastern corridor. Special attention should 

be paid to collecting consistent field data, given that current databases for the area do not 

have the required information. 

5.3.4 Vegetative Survey Deficiencies 

GCU plans to harvest 645 km2 of old growth boreal forest (>120 years) that crosses 

through wintering woodland caribou habitat at two separate locations. Old growth forests 

are critical for maintaining ecological diversity and integrity, however they are becoming 

scarce due to poorly managed natural resource harvesting activities; forestry and mining. 

The intent of the vegetative study was to identify eco-regions/sites, near the primary 

Springpole campsite. Background research and desktop analysis for the study involved 

searching the Forest Resource Inventory (FRI) managed by the OMNR (the FRI is only 

current up to 2000) and comparing that data to the OMNRs ecosites concepts (Ecosites of 

Ontario, 2009) 

The study failed to investigate which vascular plants and mosses may be present in the 

area, and did not reference which species may be endangered, threatened, special concern 

or extirpated: list available through Ontario Species at Risk database and OMNR (2004). 

The particular region the GCU seeks to develop is old growth boreal forest, and many of the 

vascular plants and mosses identified for protection may be present and thriving within 

this region. Below is a complete list of Ontario species at risk vascular plants that may be 

present in the area: 

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March 30, 2013 

Table 3. Ontario Species At Risk Vascular Plants identified by the Committee on the Status 

of Endangered Wildlife in Canada (COSEWIC) and Ontario Ministry of Natural Resources 

(2004). 

Endangered Threatened Special Concern Extirpated 

American Ginseng 

Bird’s-foot Violet 

Bluehearts 

Blunt-lobed Woodsia 

Butternut 

Cucumber Tree 

Drooping Trillium 

Eastern Prairie Fringedorchid 

Eastern Prickly Pear Cactus 

Engelmann’s Quillwort 

False Hop Sedge 

Few-flowered Club-rush 

(Bashful 

Bulrush) 

Forked Three-awned Grass 

Gattinger’s Agalinis 

Heart-leaved Plantain 

Hoary Mountain-mint 

Horsetail Spike-rush 

Juniper Sedge 

Large Whorled Pogonia 

Nodding Pogonia 

Pink Milkwort 

Pitcher’s Thistle 

Purple Twayblade 

Red Mulberry 

Scarlet Ammannia 

Showy Goldenrod 

Skinner’s Agalinis 

Slender Bush-clover 

Small-flowered Lipocarpha 

Small White Lady’s-slipper 

Small Whorled Pogonia 

Spotted Wintergreen 

Toothcup 

Virginia Goat’s-rue 

Western Silvery Aster 

White Prairie Gentian 

Wood-poppy 

American Chestnut 

American Water-willow 

Branched Bartonia 

Colicroot 

Common Hoptree 

Crooked-stem Aster 

Deerberry 

Dense Blazing Star 

Dwarf Hackberry 

Goldenseal 

Hill’s Pondweed 

Kentucky Coffee-tree 

Lakeside Daisy 

Round-leaved Greenbrier 

White Wood Aster 

Wild Hyacinth 

Willowleaf Aster 

American Columbo 

American Hart’s-tongue 

Fern 

Blue Ash 

Broad Beech Fern 

Climbing Prairie Rose 

False Rue-anemone 

Green Dragon 

Riddell’s Goldenrod 

Shumard Oak 

Swamp Rose-mallow 

Tuberous Indianplantain 

Illinois Tick-trefoil 

Spring Blue-eyed Mary 

http://www.ontarionature.org/discover/resources/PDFs/id_guides/SAR_brochure.pdf 

5.3.4.1 Vegetative Survey Methodology Deficiencies 

The Terrestrial and Wetland Ecosites of Northwesern Ontario have classified Trout Lake 

Forest ecosites, based on soil and vegetative characteristics: classification conducted 

through photo-interpretation and limited field sub-sampling. 

The vegetative fieldwork study consisted of selecting 23 land plots in order to verify 

outdated FRI data. The vegetative and soil composition of each ecosite was sampled and 

compared to existing FRI data; identified as verified or unclassified. Of the 23 plots 

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March 30, 2013 

sampled, 53% of them were unclassified and did not match up with existing FRI data, 

which was attributed to “lack of accurate data for the current FRI (Terrestrial Baseline 

Report, page 3-3).” 

Overall, there are a variety of areas where the study was deficient; 

All 23 selected ecosites were within a small region of the larger study area, and were 

not representative of the overall study area or the eastern corridor; 

The study failed to determine what vegetative species were present in the area 

through field work; 

No reference made to the forest fire and cumulative impacts to vegetation; 

No discussion regarding harvesting 645 km2 of timber and its impacts on vegetative 

biodiversity; 

No discussion on how the eastern corridor would impact endangered, threatened, 

special concern or extirpated vegetative species; 

No environmental protection and mitigation measures proposed for vegetative 

species at risk; 

No discussion on potentially important wildlife plant food sources that may be 

compromised; 


As with the other terrestrial baseline studies, conclusions were drawn about the low 

impact of the project on terrestrial parameters, based on flawed methodology and lack of 

data: “None of these stands have been found to occur within the RSA, therefore the 

potential environmental effects are considered to be negligible and no mitigation is 

required (Draft ESR, page 3-28).” 

Based on the narrow analysis used to derive these unsubstantiated conclusions, it is 

fair to say that this study was unscientific, poorly conducted and results are 

inconclusive. 

Recommendation: GCU needs to conduct a thorough fieldwork vegetation study in 

conjunction with First Nation communities that documents all ecosites, plant species and 

communities relevant to the eastern corridor. 

Recommendation: During the next vegetation study, GCU will document the plant species 

that are listed in the Ontario Species At Risk - Vascular Plants list, and those that are used 

within First Nation traditional purposes. 

Recommendation: The road closure and rehabilitation plan developed for the eastern 

corridor needs to have all plant communities well documented, and outline how revegetation 

will occur in order to return those sites back to their original states. 

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March 30, 2013 

5.4 Aquatics Baseline Report Deficiencies 

Mining activities cause significant contamination of water resources, and generally proceed 

with little regard for the environment. GCU has been conducting exploration activities in 

Springpole for many years, however their environmental analysis of the area was 

conducted in 2011. Any results generated from the Springpole area aquatics study 

will be biased, as drilling activity on the lake may have already altered aquatic 

baseline values. 

After a preliminary review of the aquatics study and technical report findings, there are a 

few issues pertaining to reporting in the ESR; 

1) The Birch River crossing was not assessed within the Aquatics Baseline Study. The 

site is referenced as being important for all season and spawning habitat for fish. 

“The Birch River has its outflow at the eastern end of Springpole Lake, draining Springpole 

into Fawcett Lake. The Birch River is known to provide some of the most important walleye 

spawning habitat in the study area and may serve as year-round habitat for walleye. Lake 

trout, northern pike and whitefish all likely show seasonal use of the river, as either feeding 

(lake trout, northern pike, whitefish) or spawning (whitefish) habitat. The drainage from 

Cromarty Lake into the southwest corner of Springpole Lake also represents important 

walleye spawning habitat in the study area (Draft ESR, page 2-35).” 

2) The ESR does not discuss surface water results within the ESR, as it is not directly 

related to the eastern corridor. Given that all of the technical report studies were 

conducted at locations not relevant for the eastern corridor, it is only fair that 

surface water results also be analyzed here. 

Surface water results from the Aquatics Baseline Report (page 24); 

Total phosphorus was higher than Provincial Water Quality Objectives (PWQO) 

of 0.02 mg/L at sites; SW-6 (0.026 mg/L) in Q1, SW-9 (0.023 mg/L) in Q2, SW-4 TOP 

(0.022 mg/L), SW-5 TOP (0.032 mg/L), SW-9 (0.049 mg/L), and SW-10 (0.042 mg/L) 

in Q3. 

Dissolved mercury was higher than the PWQO of 0.2 μg/L at sites; SW-3 (0.43 

μg/L) and SW-5 (0.27 μg/L) in Q1, as well as in SW-5 MID (0.29 μg/L) in Q3. 

Total cadmium was higher than the PWQO of 0.1 μg/L (sample hardness 

measured at less than 100 mg/L) at SW-11 (0.4 μg/L) in Q1. 

Total iron surpassed the PWQO of 300 μg/L at sites SW-9 (850 μg/L) and SW-10 

(970 μg/L) in Q3. 

Note: technical report did not indicate where the actual sampling locations were. 

The report indicates that total phosphorous, dissolved mercury, total cadmium and 

total iron are already elevated in the study area. No rationale as to why these 

elements were already elevated in surface water samples within the technical report 

and ESR, particularly the heavy metals; mercury, cadmium and iron. 

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March 30, 2013 

Underwater drilling by GCU has been occurring within the Springpole area for many 

years, without monitoring or environmental assessment. Drilling activities are 

associated with causing increased leaching of heavy metals into water, thus 

potentially explaining why there are higher levels of heavy metals observed within 

Springpole study area. 

http://www.safewater.org/PDFS/resourcesknowthefacts/Mining+and+Water+Pollution.p 

df 

3) Toxicity testing only analyzed 3 surface water sites for acute toxicity to Daphnia 

magna and Oncorhynchus mykiss, using pass/fail assessment. 

Fish were not assessed for high levels of detected phosphorous, mercury, 

cadmium and iron, which were detected as high from surface water analysis; 

Deep water samples were not assessed for acute toxicity to Daphnia magna and 

Oncorhynchus mykiss; 

Reference material used to interpret toxicity results are outdated; 1989, 2000; 

Should have conducted a combination of toxicity tests on varied species; 

o Subchronic toxicity 

o Chronic toxicity 

o Carcinogenicity 

o Reproductive toxicity 

o Developmental toxicity 

o Neurotoxicity 

o Genetic toxicity 

Even though toxicity testing was extremely limited, the technical report made the 

following statement: “Toxicity tests performed on water collected from Springpole Lake 

indicated that it was non-lethal to the species Daphnia magna and Oncorhynchus mykiss, as 

no mortalities were reported. This suggests that Springpole Lake is currently capable of 

supporting a healthy aquatic ecosystem with no acute toxicity (Aquatic Baseline Report 

2011, page 79).” 

As stated previously in this report, lack of data and poor methodology do not provide 

justification to arrive at conclusions not supported by the evidence, as was the case with 

the aquatics baseline studies. 

Aside from water quality issues, there is the potential for deforestation to lead to other 

potential water related issues, causing alteration and destruction to aquatic habitat; 

increased sedimentation, erosion, etc. The below table summarizes all the issues 

identified within the ESR which pose a serious risk to aquatic habitat, and are not 

insignificant. 

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March 30, 2013 

Table 4: Alterations and destruction to aquatic habitat are also predicted in the ESR 

resulting from eastern corridor construction and operation activities (Draft ESR, page 3- 

31). 


Potential stream flow 

alterations may result from: 

Alterations to lake, pond, and 

stream water quality may 

result from: 

Destruction/Displacement of 

Fish Habitat may result from: 

GCU Related Activity 

Increased surface run-off during storm events due the 

clearing of vegetation. The removal of vegetation is 

known to decrease the rate at which water infiltrates 

the soil and increases run-off volumes, making small 

streams/creeks more vulnerable to flooding during 

storm events. 

 

 

 

 

 

Alteration of flow regimes caused by improperly 

installed culverts and addition of aggregates. 

Improperly constructed road crossings are known to 

increase erosion and gradients in downstream areas 

and can also impede flow with insufficient culvert size 

or when improperly installed 

Elevated levels of Turbidity, Total Suspended Solids, 

and Conductivity due to increased levels of erosion 

and sedimentation caused by the removal of riparian 

vegetation. 

Increased water temperatures during the summer 

months due the removal of riparian vegetation may 

increase the solar input to a stream causing water 

temperatures to increase above normal temperatures. 

Furthermore, increased levels of Total Suspended 

Solids caused by sedimentation and erosion also 

increase water temperatures as they retain more solar 

radiation. 

Improperly constructed road crossings will impede 

fish migration and alter substrate type due to changes 

in the flow regime. 

Changes in water temperatures due to erosion and 

sedimentation will affect species that are not resilient 

to warmer temperatures. Increased sedimentation will 

also fill in pools and under-cut banks, as well as 

covering essential spawning habitats such as gravel 

and cobble shoals. 

The mitigation measures proposed by GCU to remedy all the above potential impacts to 

aquatic habitat and flow alterations include implementing a buffer around lakes, ponds and 

streams and having an “experienced and respected professional engineer” as opposed to an 

inexperienced and disrespected unprofessional engineer (!?!?). The mitigation measures 

proposed do not discuss continued monitoring or follow-up actions if any of the above 

impacts are detected. 

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March 30, 2013 

The ESR regards all potential impacts to lakes, rivers and streams to be low, without 

providing any rationale, or having the evidence to back up those claims. 

Recommendation: GCU needs to conduct a thorough aquatics study, taking into account 

the above-mentioned parameters, relevant to all Springpole exploration activities. The 

study should assess the environmental impacts for the duration of Springpole exploration 

project; 10-20 years. 

Recommendation: The next aquatics baseline study performed by GCU needs to take 

information gathered from the hydrology and terrestrial baseline studies and evaluate 

their combined effect on aquatic habitat, surface and deep water quality, species diversity, 

species reproduction, hydrology, etc. 

Recommendation: If GCU has determined that there are high levels of heavy metals 

detected in Springpole, all activities that could potentially contribute to increased heavy 

metal leaching must be stopped. 

5.5 Hydrology Baseline Report Deficiencies 

Hydrology is the study of water movement, quality and distribution. Typical hydrological 

investigations include an assessment of ground water quality, character, composition and 

potential for contamination. The hydrological study conducted by GCU did not evaluate 

any parameters associated with ground water quality, or identify which aquifers may be 

impacted by Springpole drilling activity. 

The aquatics study should have been conducted in conjunction with the hydrology study in 

order to properly assess for downstream or ground water contamination: aquatics study 

revealed that heavy metals were already elevated in Springpole. 

In the Preliminary Economic Assessment released March 25, 2013, GCU states that 

Springpole exploration construction will include: “project infrastructure, dike construction 

and dewatering activities, open pit development, procurement of mining and milling 

equipment, and mill construction (GCU Preliminary Economic Assessment – March 25, 

2013).” 

NO WHERE in the ESR or Technical reports (hydrology or aquatics) does GCU discuss 

dike construction, dewatering activities, open pit development or the required water 

and sewer infrastructure required to pursue continued/advanced exploration, that 

would occur pending approval of the eastern corridor. 

It is evident for the Preliminary Economic Assessment, that GCU is NOT being fully 

transparent about the full scope of the Springpole exploration project, nor the true 

environmental and socio-economic ramifications related to project activities. 

Recommendation: GCU needs to fully disclose ALL Springpole related exploration 

activities, inclusive of the eastern corridor, in a single document complete with technical 

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March 30, 2013 

report findings related to water quality, hydrology, aquatic habitat, terrestrial values and 

socio-economic factors. 


The ESR is comparing the GCU road to natural erosion processes such as fires, implying 

that an industrial corridor used for heavy trucks allows for the development of 

biodiversity. The ESR concludes that timber harvesting results in biological diversity and 

ecological function (ESR page 54). 

Given that the data derived from terrestrial baseline studies and desktop analysis for flora 

and fauna were flawed and incomplete, it stands to reason that no firm conclusions 

regarding habitat fragmentation can be drawn in the ESR. 

For example: Information used to assess woodland caribou habitat is based off of an 

incomplete OMNR study from 2000 and other references that are between 15 and 29 years 

old. ESR discussion of woodland caribou habitat fragmentation is limited and identified as 

not significant. 

Recommendation: GCU needs to complete a thorough terrestrial baseline study that 

specifically addresses all contributing factors to habitat fragmentation for all species, not 

just woodland caribou. The study should evaluate habitat fragmentation resulting over 10- 

20 years, as a result of anticipated Springpole exploration related activities; eastern 

corridor develop and exploration. 

5.7 Environmental Protection and Mitigation Plans 

GCU states that mitigation measures are planned and will proceed with future consultation 

with affected stakeholders. To date there is no information available on what guidelines 

are in place to ensure that consultation with stakeholders will take place, and who will 

mediate any dispute. In general, most environmental issues are regarded as resolved by 

GCU, despite evidence showing that the technical studies used to arrive at those 

conclusions are deficient. 

Table 6-1: Mitigation Measures for Potentially Significant Negative Effects/Concerns, 

proposing a variety of mitigation measures. In order for the mitigation measures to be 

effective the following needs to occur; 

 

 

 

Guidelines for the proposed mitigation measures needs to be developed; 

A communications strategy between Stakeholders, First Nations and GCU needs to be 

developed, whereby all parties are routinely kept informed of all mitigation, monitoring 

and follow-up activities and corresponding reports; 

Monitoring and follow-up procedures need to be developed and corroborate with the 

communication strategy and mitigation measure guidelines; 

The environmental mitigation measures proposed in general simply state that monitoring 

will take place, but no reference is made to follow up activities and communicating findings 

of those monitoring and follow-up programs to Stakeholders, First Nation communities and 

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March 30, 2013 

the OMNR. Wildlife mitigation plans are somewhat proposed in the ESR, but lack 

description, monitoring and follow-up plans. 

Recommendation: GCU in conjunction with stakeholders and First Nation communities 

needs to draft an all-in environmental protection and mitigation plan that addresses all 

environmental issues, and how the monitoring, data analysis/interpretation, report writing 

and mitigation process will take place. 

Recommendation: GCU needs to establish a communications plan with Stakeholders, First 

Nation communities, OMNR and the public, that outlines how issues of environmental and 

socio-economic concern will be addressed, 

5.8 Cumulative Impacts Assessment and Residual Effects 

The cumulative impacts assessment conducted by GCU is completely insufficient, and is 

only referenced in a few locations throughout the ESR; 

page xi “Reduced potential for cumulative effects in the region compared…” 

page 7 “increased potential for cumulative effects to biological values…” 

Table 2-1 “exert greater cumulative effects because it would…” 

Table 2-1 “which creates a larger cumulative impact and affects…” 

 

Table 2-1 “would result in a greater cumulative impact for the region..” 

Page 14 “reduction in the potential for cumulative effects in the region..” 

Table 2-2 “in a greater cumulative impact for the region because…” 

Page 21 “Reduced potential for cumulative effects in the region compared..” 

Page 22 “resultant reduction for cumulative effects in the region…” 

No cumulative impacts assessment was conducted for this project, as is evidenced by a 

complete lack of data available within the ESR and technical reports. GCU discusses their 

alliance with Domtar (Forestry) and road use synergies, but there is no further exploration 

into how joint use of the corridor will impact socio-economic and environmental 

parameters. 

The ESR references a variety of potential environmental impacts to wildlife resulting from 

corridor use and include; 

Mortality as a result of construction; 

Mortality as a result of vehicle collisions; 

Modification of behaviour; 

Habitat fragmentation and loss; 

Displacement due to invasive species; 

Increased predation. 

Areas required for a cumulative impacts assessment for the project; 

Long-term study that evaluates the socio-economic and environmental impacts over 

a ten year period for projected eastern corridor; 

Cumulative assessment needs to consider but is not limited to; 

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March 30, 2013 

o Forestry pressures; 

o Increased traffic; 

o Seasonal and all-season eastern corridor use schedule; 

o Traffic load on seasonal and all-season eastern corridor; 

o Impact of herbicide use by forestry company; 

o Water contamination issues, changes to hydrology, ground water quality, 

aquatic environment, etc. 

o Forest fires and other natural events; 

o First Nation traditional land use, Aboriginal and Treaty rights; 

o Tourism; 

o Wildlife hunting and predation; 

o Invasive species; 

o All mining activities and establishment of a larger Springpole base camp, etc. 

Prior to any project going forward, a thorough cumulative impacts assessment 

should be completed, taking into account the above mentioned parameters. 

Recommendation: GCU complete a thorough cumulative impacts assessment, taking into 

account the above mentioned parameters, that evaluates the long-term impacts of the 

project over the anticipated duration of Springpole exploration; 10-20 years. 

5.9 Future Corridor Upgrades 

In all discussions to date with Stakeholders, GCU has maintained that they are looking to 

build a seasonal winter road. Closer inspection of the ESR indicates that GCU is not being 

fully transparent with stakeholders, First Nations, etc, as the ESR makes reference to 

establishing an all season road. 

“Water crossings along the eastern corridor would be built to a primary road standard 

where possible to facilitate future potential upgrades of the winter operational road to an 

all-weather access road at a later date and also to minimize environmental risk associated 

with less robust water crossing structures (ESR page vii).” 

Gravel placement over this winter operational road and upgrading it to an all-weather 

access road is not part of the currently proposed Project. “Pending continued positive 

exploration results and on-going consultation, the gravel placement that would be 

required to upgrade this winter operational road to an all-weather access road may 

be proposed at a later date (ESR page vii).” 

Recommendation: GCU needs to outline a 10-20 year plan for the Springpole Gold Project, 

inclusive of the eastern corridor, outlining their full intentions for Springpole, the eastern 

corridor and collaborations with other resource harvesting companies; Domtar. 

5.10 GCU and Domtar Synergies 

GCU emphasizes that Domtar may use the eastern corridor at some point in the future, 

without providing specific information as to when; 2014-2019 period. Review of the 

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March 30, 2013 

Domtar 2014-2019 Forest Management map, shows that Domtar is not anticipating to 

harvest in the greater eastern corridor region, during 2014-2019 period. So far it is not 

clear to what extent Domtar will use the eastern corridor. 

GCU is currently seeking a 3 year exploration permit for Springpole. If continued 

Springpole exploration unsuccessful, the permit will terminate Springpole activity in 2016. 

Therefore making the assumption that GCU and Domtar will use the road during the same 

period is premature. 

Furthermore, in the event that GCU and Domtar use the eastern corridor simultaneously, 

another environmental assessment will have to be conducted to evaluate the cumulative 

impacts of dual corridor use. 

Recommendation: GCU be transparent with Stakeholders, First Nation community, OMNR 

and the public regarding the full extent of their synergistic relationship with Domtar, and 

identify the following; 

When synergistic eastern corridor use will take place down to the year; 

How much financial or administrative assistance Domtar is providing to GCU for 

eastern corridor development; 

Outline the road closure and rehabilitation plan in the event share use of the eastern 

corridor. 

Recommendation: GCU needs to provide detailed maps showing the 2014-2019 GCU 

eastern corridor and Domtar harvesting plans, identifying exact locations of where Domtar 

activities will take place in reference to the eastern corridor. 

Recommendation: GCU will need to complete a cumulative impacts assessment for the 

eastern corridor if both GCU and Domtar intend to use the corridor over the same period; 

2014-2019. 

5.11 Corridor Rehabilitation 

When any land is subject to industrial exploitation, leading to environmental degradation, 

an environmental rehabilitation plan (ERP) is required of the proponent to ensure 

accountability. The ERP must employ strategies to restore the environment to its original 

state; structure, properties, topography, texture, etc. Instances where the environmental 

damage is anticipated to be significant, the proponent is required to set-aside a reclamation 

bond” with the OMNR, to cover costs associated with project decommissioning and 

rehabilitation. 

The eastern corridor intends to destroy 645 km 2 of old growth boreal forest, crossing 

through known woodland caribou habitat. Despite the rather large project area, the ESR 

makes no direct reference to having a rehabilitation strategy or plan in place, and 

instead puts the responsibility onto First Nations, Domtar, Stakeholders and OMNR. 

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March 30, 2013 

“This rehabilitation that GCU is prepared to undertake is pending input from other parties 

that include, but are not limited to, Cat Lake First Nation, Domtar and MNR. It is 

understood that some of these parties may potentially have an interest in having some or 

all of the road and water crossings remaining in place. This modified use of the eastern 

corridor would be subject to a new environmental assessment and approvals process (ESR 

page 49).” 

GCU further avoids addressing the issue of eastern corridor rehabilitation directly, by 

stating that: “In the event that the Springpole Gold Project becomes fully permitted and 

proceeds to a production phase, the rehabilitation of the access corridor would be within the 

scope of the Closure Plan that is filed pursuant to Part VII of the Mining Act and MNDM’s 

requirements regarding the financial assurance provision for the entire development (ESR 

page 49).” 

Review of Part VII of the Ontario Mining Act provides no specific recommendations 

for corridor rehabilitation. Given that GCU seeks to implement a road through 645 

km 2 of valued forest, Stakeholders are requesting the GCU be required to place a 

“Reclamation Bond” for 100% of the rehabilitation costs with the OMNR. GCU must 

also disclose the total amount required for rehabilitation of 645 km 2 of land to 

Stakeholders, First Nation communities, etc. 

Note: According to the Springpole Preliminary Economic Assessment, roughly $20 million 

is planned to be set aside for Springpole mine closure and rehabilitation: No indication of 

how much reserved for eastern corridor rehabilitation. To date, GCU has not indicated how 

much it will cost to put in a seasonal road, nor the amount required to rehabilitation 645 

km 2 of land. 

This raises serious questions of whether GCU understands how much it will cost to 

rehabilitate the eastern corridor, timelines associated with rehabilitation and if they 

even have the financial capital sufficient for the undertaking. 

If the eastern corridor is constructed, and GCU lacks the capital to initiate 

rehabilitation, tax payers will end up covering the cost! 

Recommendation: The OMNR require that GCU secure a reclamation bond for 100% of 

the costs associated with rehabilitation of the eastern corridor. 

Recommendation: The OMNR and GCU will disclose to Stakeholders, First Nation 

communities and the public the amount required to rehabilitate 645 km 2 of old growth 

boreal forest and woodland caribou habitat. 

Recommendation: GCU develop a road closure and rehabilitation plan for the eastern 

corridor in conjunction with Stakeholders, First Nation communities and the public, which 

is to be developed prior to approval of the project. 

39


March 30, 2013 

5.12 GCU Preliminary Economic Assessment and Stock Volatility 

Stakeholders are concerned that GCU will not have sufficient funds to cover the costs 

associated with rehabilitation of the eastern corridor in the event that Springpole 

exploration is no longer viable. 

The GCU Preliminary Economic Assessment was released on March 25, 2013; 1 week prior 

to final submission for ESR comments. The following is the indicated and inferred gold and 

silver mineral resource identified at Springpole to date: 

GCU: Management Discussion & Analysis, August 31, 2012, page 7: 

Classification Tonnage 

(million 

metric 

tonnes 

Gold Grade 

(grams per 

tonne) 

Silver Grade 

(grams per 

tonne) 

Gold 

Contained 

(million troy 

ounces) 

Silver 

Contained 

(million troy 

ounces) 

Indicated 128.2 1.07 5.7 4.41 23.8 

Inferred 25.7 0.83 3.2 0.69 2.7 

Based on the below information extrapolated from GCU documents posted on the GCU 

website (www.goldcanyon.ca), Stakeholders would like to know if the below references to 

company evaluation are correct and if sufficient funds are available to pursue road 

construction, operation, environmental monitoring and rehabilitation activities? 

Q3-Financial Statements, Nine Month Period Ended August 31, 2012: 

According to the most recent financial statement issued by GCU as of August 31, 2012, the 

3 rd quarter statement indicates GCU has $11,493,769.00 (Cdn) working capital, $12, 

749,732.00 (Cdn) cash and $24,450,978. 00 (Cdn) accumulated deficit. 

“Going Concern of Operations: The Company has not generated revenue from 

operations. The Company incurred a net loss of $3,340,521 during the nine months 

ended August 31, 2012 and an accumulated deficit of $24,450,978. As the Company is in 

the exploration stage, the recoverability of the costs incurred to date on exploration 

properties is dependent upon the existence of economically recoverable reserves, the ability of 

the Company to obtain the necessary financing to complete the exploration and development 

of its properties and upon future profitable production or proceeds from the disposition of the 

properties and deferred exploration expenditures. The Company will periodically have to 

raise funds to continue operations and, although it has been successful in doing so in the past, 

there is no assurance it will be able to do so in the future (Q3-Financial Statements, Nine 

Month Period Ended August 31, 2012, page 8).” 

Investors have raised concerns regarding weak GCU share price (April 1, 2013: 

$0.48/share) and higher than normal trading volume. GCU has also made public that the 

company only has $10 million (Cdn) in reserve (an amount that would barely cover 

summer operation costs) and does not communicate the $24,450,978.00 in accumulated 

deficit. Below are recent excerpts from GCU’s website (www.goldcanyon.ca - accessed April 

1, 2013). 

40


March 30, 2013 

Note: the Preliminary Economic Assessment does not comment on the $24,450,978 

accumulated deficit. 

February 6, 2013 – Gold Canyon Comments on Recent Share Price and Trading 

Volume Concerns: 

“In response to enquiries, Gold Canyon Resources Inc. (TSX VENTURE:GCU) 

(PINKSHEETS:GDCRF) ("Gold Canyon" or "the Company") wishes to comment on the 

Company's recent share price weakness and higher than normal trading volume, 

which over the past several months has raised concerns amongst its investors 

(www.goldcanyon.ca - Accessed April 1, 2013).” 

“Gold Canyon has cash reserves of more than (Cdn)$10 million, considered to be 

sufficient to fund current operations through the short to medium term without the 

immediate need to raise more capital. In the circumstances, management believes that 

Gold Canyon's current share price significantly undervalues the Company, and with the 

support of Gold Canyon's board of directors, is currently examining various initiatives and 

strategic options to remedy this situation (www.goldcanyon.ca - Accessed April 1, 2013).” 

There is a strong possibility that GCU requires the eastern corridor to build 

Springpole property value, improve investor confidence and increase stock price, in 

order to afford continued exploration at Springpole. 

If this is the case, then the eastern corridor is NOT required to directly facilitate 

exploration at Springpole. 

In the event that eastern corridor development is approved and GCU stocks continue 

to fall, financial hardship will prevail, leaving the company without the financial 

means to rehabilitate the eastern corridor. Unless a reclamation bond is secured 

prior to GCU commencing eastern corridor development, there is a strong possibility 

that tax payers will have to cover the eastern corridor rehabilitation costs: which 

will be much more than $10 million. 

Recommendation: GCU needs to fully disclose the amount of working capital and 

accumulated deficit to Stakeholders, First Nation communities, the public and OMNR prior 

to approval for the eastern corridor. 

Recommendation: If GCU is working jointly with Domtar on the development of the 

eastern corridor, it should be fully disclosed to what extent and how much financial 

assistance Domtar will provide for rehabilitation of the eastern corridor. 

41


6 Summary of Recommendations 

March 30, 2013 

 

 

 

 

 

 

 

 

 

GCU needs to complete a thorough environmental assessment for all environmental 

parameters; terrestrial, aquatic, hydrological, etc, utilizing tested methodologies 

that allow for reproducibility and statistical analysis. 

GCU needs to conduct thorough environmental baseline studies in conjunction with 

First Nation communities, and jointly engage with those communities throughout 

the planning, hiring, implementation, analysis and report writing stages of all 

studies. 

All environmental studies conducted must be done so in conjunction with First 

Nation communities and OMNR, and assess the environmental impacts associated 

with all aspects of Springpole exploration over the course of 10-20 years; 

anticipated period of operations. 

GCU needs to conduct an all-in cumulative impacts assessment for all environmental 

parameters, investigating the long-term impacts (10-20 years) of GCU Springpole 

exploration activities. 

GCU needs to establish the following documents in conjunction with Stakeholders, 

First Nation communities, OMNR, environmental organizations, etc; 

o Good Neighbour Policy 

o All-in Environmental Protection and Mitigation Plan 

o All-in Water quality, hydrology, aquatic habitat and terrestrial implications 

analysis 

o Eastern corridor rehabilitation plan 

GCU needs to provide an all-in document outlining their current and anticipated 

financial constraints as it relates to all Springpole related activities, highlighting 

overall stock weakness, incurred debt, available cash, assets, etc. 

OMNR should require GCU to secure a reclamation bond for 100% of the costs 

associated with closure and rehabilitation of the eastern corridor. 

OMNR should not permit GCU for eastern corridor development based on; 

o Incomplete environmental assessment 

o Lack of transparency with financial instability of the company 

o Poor rationale to pursue the project 

In the event that OMNR wants to pursue approval of the GCU eastern corridor 

project, a PART II ORDER should be implemented, elevating the project to a Class D 

Environmental Assessment, thereby requiring an independent and thorough 

environmental assessment. 

42

Schedule 1: GCU Response to General Concerns stated in TFTO Submission 

GCU Response to TFTO Submission 

TFTO 

Submission 

(TFTO Section 

reference) 

Overview 

(Section 1) 

Inadequate First 

Nation 

Consultation 

(Section 1.2) 

Major concerns 

(Section 2.2) 

Lack of a Good 

Neighbour Policy 

(Section 4.1) 

GCU Response 

The TFTO Submission repeatedly refers to clearing of 645 km 2 of forested 

land and this is incorrect. The entire 43 km road corridor would require 

0.645 km 2 of clearing over a 43km corridor (43 km x 0.015 km). Of this 

0.645 km 2 of proposed clearing, approximately 0.33 km 2 is already 

approved to be cleared in the Trout Lake Forest Management Plan 

(approximately 22km x 0.015 km). 

The record of stakeholder consultations is included in the final ESR. 

The TFTO Submission speculates about potential impacts of the 

development of a mine. That speculation is beyond the scope of this ESR. 

If GCU seeks to develop the Springpole Gold project into a mine, a new 

environmental assessment process that will assess the broader impacts 

and benefits of such a development. 

The record of stakeholder consultations is included in the final ESR. 

The Crown has a legal obligation to consult Aboriginal groups. GCU has 

performed some of the procedural aspects of that consultation as 

delegated by the Crown. Those consultations are set out in detail in the 

final ESR. GCU remains strongly committed to working with Aboriginal 

groups whose Aboriginal and/or Treaty Rights may be affected by GCU’s 

activities. 

The issues noted in the TFTO Submission are dealt with in the final ESR 

and reasonable mitigation measures are proposed in the final ESR (see 

Tables 3.1 and 3.2 final ESR). 

GCU is willing to agree to a good neighbour policy with TFTO. In 

November 2012, a TFTO representative agreed to prepare a draft policy 

for discussion between GCU and TFTO. GCU has confirmed its 

willingness to agree to such a policy in subsequent discussion with TFTO, 

but nothing further has been proposed to date. Entering into such an 

agreement is a commitment in the final ESR. 


Response to TFTO Submission for Springpole Access Corridor Final ESR 

April 2013 Schedule 1/- 1-

GCU has hired qualified, independent consultants to conduct baseline 

environmental studies with direct participation of First Nation technicians. 

The baseline environmental work surpasses what is typically required for 

an environmental assessment for a road corridor of this nature. 

Alleged Deficient 

Baseline Studies 

(Sections 5.3-5.5) 

GCU offered in the final ESR to share the “working draft” baseline studies 

that GCU has initiated in the larger region. These “working draft” studies 

are simply factual reports that are intended to characterize environmental 

and socio-economic conditions in the larger region to support a potential 

future environmental assessment process for a mine development. The 

“working draft” studies contain no impact predictions and are not required 

to inform the environmental assessment for this Project, they simply 

supplement the compulsory information that has been provided in the final 

ESR. 

The baseline environmental studies identify values that should be avoided 

by the road corridor (see Figure 2-1 of the final ESR). Those studies also 

document the current conditions used in the impact analysis for the winter 

road. That analysis is presented in Appendix 4 of the final ESR. 

The TFTO Submission does not identify any material deficiency with the 

baseline studies and associated impact analyses that were relied on and 

incorporated as Appendix 4 to the final ESR. 

Assessment of 

Potential 

Cumulative 

Impacts 

(Section 5.8) 

Future use of the 

road 

Although not specifically required by the Class Environmental Assessment 

process, potential cumulative impacts were considered throughout the final 

ESR and the preferred corridor has been selected to minimize cumulative 

impacts. This is articulated throughout the final ESR. The nature, intensity 

and duration of the project are appropriate for a Class Environmental 

Assessment and it is not a unique undertaking that warrants an individual 

(Category D) environmental assessment. 

Concerns regarding future use or upgrading of the road and eventual 

decommissioning are addressed in the final ESR. Full disclosure is 

provided regarding collaborations and future plans. 

(Sections 5.9, 

5.10) 




Preliminary 

Economic 

Assessment 

(“PEA”) and GCU 

Financial Status 

(Section 5.12) 

The economic potential of the Springpole Gold Project is subject to 

ongoing assessment as information becomes available. The March 25, 

2013 Preliminary Economic Assessment provides the most recent 

information and provides further justification to continue exploration work. 

The Project will safely and effectively enable further definition work on the 

gold deposit. That work will allow GCU to refine the economic information 

available to date and prepare a pre-feasibility and/or feasibility study for 

the development of the gold deposit into a mine. 

GCU is a publicly traded company and is subject to strict regulation 

regarding financial disclosure. 

First bullet: The baseline studies and impact analyses were completed with 

input from the provincial government, and in accordance with accepted 

practice. That information was included in the final ESR. TFTO’s 

recommendation proposes an environmental assessment more relevant to 

that warranted for a mine development and far beyond what is required for 

the proposed Project of an access road. 

Second bullet: The record of consultation is included in the final ESR. GCU 

is committed to working with Aboriginal groups whose rights may be 

impacted by GCU activities, and continues discussions to formalize its 

working relationship with the affected First Nations. 

TFTO Summary of 

Recommendations 

(Section 6) 

Third bullet: The environmental studies necessary for the assessment of 

the road project are included in the final ESR. TFTO’s recommendation 

would impose obligations far beyond those warranted or required for the 

impact of a seasonal access road. 

Fourth bullet: Although not specifically required by the Class 

Environmental Assessment process, potential cumulative impacts were 

considered throughout the final ESR and the preferred corridor has been 

selected to minimize cumulative impacts. The nature, intensity and 

duration of the Project are appropriate for a Class C Environmental 

Assessment and it is not a unique undertaking that warrants an individual 

(Category D) environmental assessment. 

Fifth bullet: 

The only outstanding recommended item is the Good Neighbour Policy. 

TFTO committed to GCU that it would provide a draft policy for discussion, 

but none has been proposed to date. Entering into such an agreement is a 

commitment in the final ESR. 




The basic environmental protection and mitigation measures are 

incorporated into the final ESR (Section 5 and 6), along with details 

regarding implementation (Section 8). 

Adhering to the guidance documents and procedures in the final ESR 

removes the need for the recommended impact analysis. 

The rehabilitation plan is described in Section 5.3 of the final ESR. 

Sixth bullet: Financial disclosure that may be made publicly is made on a 

regular basis on GCU’s website, in accordance with regulatory 

requirements. GCU cannot disclose financial information to TFTO that has 

not been disclosed publicly and such a request is not reasonable. 

Seventh bullet: This is addressed and this recommendation is effectively 

integrated into Section 5.3 of the final ESR. 

Eighth bullet: 

The final ESR complies with the requirements of this Class Environmental 

Assessment. 

GCU provides public disclosure on its website in accordance with 

regulatory requirements. 

The Project is aligned with provincial government objectives, as articulated 

in Section 1.3 of the final ESR. 

Ninth bullet: An individual (Category D) environmental assessment is not 

appropriate for a simple, routine undertaking such as the one being 

proposed in the final ESR. The nature of the work is well understood, the 

mitigation measures are proven and values have been identified and are 

being avoided with the proposed corridor. 




Schedule 2: 

Detailed response to TFTO Submission to Springpole Access Corridor Project Final ESR. 

Page 4 1 

1. Area to be cleared for the entire 43 km corridor of the proposed Project is only 0.645 km 2 NOT 

645 km 2 , as stated by the TFTO. Number is based on incorrect calculation of the corridor. 

(43km x 0.015 km = 0.645 km 2 ). 

0.33 km 2 of this area is already approved for clearing in the 2009-2019 Trout Lake FMP, so only 

0.315 km 2 is added by the GCU Project. 

2. DST Consulting Engineers (“DST”) has continued to conduct baseline studies throughout 2012. 

The TFTO statement implies the work was conducted only in 2011. 

3. TFTO has omitted the pre-consultation that was initiated by email on April 7, and followed up 

with phone calls and one-on-one meetings with interested parties throughout May 2012. 

4. TFTO has defined Stakeholders to be "tourist operators", but has used the term interchangeably 

throughout the report to mean all public stakeholders, tourist operators and TFTO. It is very 

unclear at times who they are referencing in their comments. 

In fact, "stakeholders" in the April 7 pre-consultation included bait fishery owners, private land 

owners, and others, identified by the MNR as having a greater interest in the proposal. In later 

consultation efforts, the list was expanded to include Provincial and Federal Ministries, NGO's, 

and other stakeholder organizations. The TFTO Submission documents the pre-consultation 

stakeholder list, not the Final ESR list. Please refer to Appendix 3 in the Final ESR for the full 

consultation list. 

5. These comments were used to develop mitigation measures for the Project, and refine the 

Project Description. GCU scaled back its original proposal and implemented significant 

mitigation measures in response to stakeholder comments - See Table 3-1 in the Final ESR. 

Some stakeholders also responded with comments/letters of support for the project. 

6. GCU and MNR delayed release of the Final ESR to convene 2 meetings with TFTO and their legal 

counsel in late January and early-February to identify and discuss any impacts they felt were 

unresolved. None were identified. Rather, they wished to discuss economic compensation and 

buyout of their operations by GCU. Their proposal was declined. 

7. Mitigation measures were adopted as described in Table 3.1 and 3.2 in ESR 

1 Page numbers referenced at the top of each page refer to the TFTO Submission page number. 




8. Like the Draft ESR, Notices were also sent via Priority Post and placed in 3 local papers - see page 

29 of Final ESR. 

9. This is not an accurate statement. The technical report that the Final ESR relies upon is included 

in Appendix 4 of the Final ESR. TFTO requested copies of the additional baseline study reports 

that are listed on page 36 of the ESR document. GCU provided TFTO any reports that did not 

contain sensitive or private stakeholder information. GCU clearly stated these were working 

draft reports that summarized work to date on the baseline studies prepared in support 

of future permit applications for the Springpole Project, and that the relevant information was 

contained in the Final ESR. 

10. OMNR were joint authors of the newspaper ads placed in the Red Lake Northern Sun News (Feb 

27), Sioux Lookout Bulletin (Feb 27) and Watatay News (Feb 28). They also sent notices to 

stakeholders for whom contact information could not be provided to GCU because of protection 

of privacy rules, as well as to First Nations identified as having an interest in the Project. 

11. Submitted February 27, 2013 

12. In this instance, "Stakeholders" refers only to TFTO 

13. GCU has constructed a winter road since 2010 to support exploration activities at the project 

site. The current location for the road is primarily lake-based, which severely limits the safe 

operation period of the access road. GCU sees continuation of this access corridor as a risk on 

both safety and environmental fronts, and wishes to develop a land-based corridor. The land 

based corridor is justifiable from a safety, environmental and cost perspective. To minimize the 

cumulative impact of developing a brand new corridor, GCU has proposed following a corridor 

which is already approved under the 2009-2019 Trout Forest FMP to the Birch River and 

following the long-range FMP corridor north of the Birch River to the extent that it is practicable, 

branching off only where the FMP corridor turns away from the Springpole property 




1. Addressed in cover letter 

Page 5 

2. This is a bold statement and is not substantiated by the facts. GCU and the Crown recognize and 

respect Aboriginal and Treaty rights, and GCU continues its discussions in that regard. 

3. Presumably TFTO has no authority to represent stakeholders beyond its own members yet the 

TFTO Submission often makes bold statements on behalf of stakeholders generally. This is 

another example of that. 

4. GCU has conducted four consultation rounds: 

April 7, 2012 - Pre-ESR Consultation: A notice was sent to a primary list of stakeholders 

identified by the MNR as having a strong interest in the Project. This was followed up in April 

through June with phone consultations and/or one-on-one meetings with interested parties to 

discuss the corridor alternatives and identify impacts the Project would have on stakeholder 

interests in the Project area. The Base Case Project Description was developed from the 

information received during this phase of consultation. 

July 21 - Pre-ESR Consultation: GCU circulated the Springpole Exploration and Access Corridor 

Base Case Project Description via mail and email to the identified stakeholders list, including 

First Nations, and via mail only to an expanded list of government agencies, NGO's, and regional 

stakeholder organizations. WFN and MNO were added to the stakeholders list by the Crown 

and were included in this mailing. Comments received during this consultation phase were used 

to develop further mitigation measures and revise the Project description for the Draft ESR. 

October 17 - Formal ESR consultation - GCU circulated the Draft ESR to the expanded Aboriginal 

and stakeholder consultation list via email and mail, and published notice in 3 local papers. 

OMNR also sent notices to Aboriginal communities and stakeholders whose contact information 

could not be released to GCU. GCU then followed up by phone and/or email with all parties on 

the consultation list to ensure the Draft ESR notice was received and the stakeholders could 

download the report for review. One-on-one meetings were conducted upon request with 

interested parties. Comments received during this phase of consultation were used to develop 

further mitigation measures and revise (scale-back) the proposed Project. The consultation list 

was updated based on the follow-up contacts - see Appendix 3 of the Final ESR. 

February 27, 2013 - Formal ESR consultation - GCU circulated the Draft ESR to the expanded 

Aboriginal and stakeholder consultation list via email, mail and postings in 3 local papers. OMNR 

also sent notices to Aboriginal communities and stakeholders whose contact information could 

not be released to GCU. Follow-up was conducted using Priority Post tracking, and phone 

calls/emails to actively engaged stakeholders to advise of the closing date, if no comments had 

been received. Hard copies of the ESR were provided upon request, and responses were 

provided for comments, questions and information requests. 




A full record of consultation is provided in the Final ESR. GCU has been soliciting feedback on 

this ESR for nearly a full year, which is more than reasonable for the scale of the Project. 




Page 6 

1. This stakeholder list is out of date, sourced from the Base Case Project Description. For an 

accurate list of stakeholders contacted by GCU, please refer to Appendix 3 in the Final ESR. 




Page 7 

1. Corridor alternatives presented during the April 7 pre-ESR consultation have not been included. 

2. The ESR relies upon the Technical report contained in Appendix 4 of the Final ESR. These 

“working draft” reports were provided to TFTO upon request, but were clearly identified as 

working drafts of baseline studies being conducted in support of future potential permit 

applications for the Springpole Gold Project. Data from these baseline studies that is relevant to 

the ESR is summarized in the final ESR. 

3. GCU initiated discussion with various Stakeholders in April 2012 to be able to incorporate their 

views in developing the Project. Throughout discussions with stakeholders, GCU has presented 

the most up to date information then available. 

4. As noted in Section 3.1.4 of the ESR, in mid-May 2012 GCU provided Open House sessions for 

CLFN, SFFN, and LSFN, to solicit feedback on the design of the field portions of the baseline 

studies. Additionally, FN technicians were hired by GCU to participate in every baseline study 

that was conducted on the property. 

5. The details of the consultation process are provided in Section 3 of the ESR. Given the scope of 

the Project, all parties have had a significant opportunity to review and provide comment. Prior 

to submission of the Final ESR, GCU-revised the Project and adopted mitigation measures to 

take into account stakeholder concerns. 

6. Some submitted letters of concern, others letters/comments in support. 




Page 8 

1. Unclear as to who is referenced as “stakeholders” here 

2. Please refer to Tables 3-1 and 3-2 in the ESR for mitigation measures developed to address 

these concerns. 

3. Additional comments: Degree of impact is speculative, Tourist Operators do not have exclusive 

rights to the use of the lands and the “wilderness” surrounding their operations. The Project is 

consistent with the responsible development of the resources in the region 

4. GCU has adopted measures to limit access, including installation of gates, maximizing setbacks, 

and signage restricting access. 

5. This is unlikely. Road use will be seasonal, and will be consistent with current use of the ice road 

on Birch Lake, which will be discontinued. 

6. The crossing was moved downstream to protect the viewscape at the popular fishing hole on 

the rapids. 

7. GCU is willing to work with TFTO on a good neighbour policy. TFTO offered to draft a policy for 

discussion but none has been forthcoming. 

8. GCU has adopted environmental protection measures that are well-established and well-proven 

on other ESRs in the region, including all FMP mitigation measures and additional site-specific 

mitigation measures as described throughout the ESR. 

9. The corridor is kept to minimum width, respecting safety. 

10. GCU has proposed access restrictions, and expects there will be less risk of theft or vandalism 

with discontinuance of Birch Lake ice road. 

11. Fragmentation and increased predation are always a concern surrounding the construction of 

any linear development in caribou habitat. GCU will decommission old drill/exploration trails 

throughout their property. This will reduce the overall cumulative km's of linear corridors in this 

area. 

12. GCU provided responses for all concerns raised in relation to the ESR, generally within 1 week of 

being advised of the concern. Mitigation measures were added to address the concerns, or 

parts of the Project were scaled back in response to feedback, as a sequential review of the 

consultation documents (Base Case Project Description, Draft ESR, Final ESR) will show. 




13. “Stakeholders” refers solely to TFTO 

14. GCU has acted in good faith and taken the views and concerns of stakeholders, including TFTO, 

into account in the final ESR. The Project has been modified and mitigation measures 

incorporated to respond to issues identified by stakeholders. At its January 21 and February 4, 

2013 meetings with TFTO, GCU requested TFTO's position on any impacts they felt were 

unresolved by the mitigation measures. Three issues were identified at the January meeting. 

These were discussed in detail during the meetings, and mitigation measures were updated and 

included in Table 3-2 of the ESR, as follows: 

• increased theft and vandalism of their properties because of increased access(item 14); 

• increased access to remote lakes (item 5); and 

• impact to business due to loss of wilderness (item 2). 




Page 9 

1. GCU must comply with all applicable legislation and is committed to doing so. 

2. Page number reference should be 35. 




Page 10 

1. Detailed comments on the water sampling and Aquatics report are provided in our comments 

on page 32 of the TFTO Submission, below. The water sampling does not support TFTO’s 

allegation that exploration activities are polluting Springpole Lake. The Aquatics report describes 

baseline conditions in contemplation of potential future mining activities and is not related to 

the access corridor ESR. 

2. TFTO does not appear to understand the purpose of the ESR. A Class C EA presents a project, 

highlights the potential environmental effects of that project, and discusses mitigation measures 

to reduce/eliminate environmental impacts. GCU must and will comply with all applicable 

legislation. 

3. These activities are not part of the proposed project, or the exploration activities being 

conducted by GCU. 




Page 12 

1. Clarification of FN facts: 

-Springpole exploration site is in Treaty 9 area 

-The Project passes through Treaty 3 area to the south 

-CLFN and SFFN are Treaty 9 First Nations 

- LSFN, WFN, and MNO (via Half-breed adhesion to Treaty 3) are included in Treaty 3. 

2. As explained to the TFTO in an email dated March 26, the archaeological reports contain 

sensitive information about the location of archaeological sites. The reports cannot be released 

to the general public by GCU. 

3. This statement is incorrect. A road corridor has been cleared of archaeological values by a 

licensed professional archaeologist. Any minor modifications to the proposed 15m road corridor 

that arise during the final review of the ESR or the subsequent approvals process would be 

cleared by a licensed professional archaeologist, as articulated in the final ESR on pages 6, 20 

and 38. 

4. The only potential water quality issues related to the construction of the road are sedimentation 

and erosion, that will be addressed by implementing MNR and DFO best management practices. 

This is stated in the ESR on page 64 and at page 6 of Appendix 4 Biological Constraints Report. 

5. These activities are not part of the proposed Project. 

6. This is a requirement for a mine development, not a winter road Project. 

7. This would be part of a mine development EA. It is not applicable for this Project because the 

scale of the Project is so small and short in duration. 




Page 13 

1. GCU is proposing to clear 0.654 km 2 in the access corridor, 0.33 km 2 of which is already 

approved for clearing in the Trout Forest FMP. 

2. Fragmentation and increased predation are always a concern surrounding the construction of 

any linear development in caribou habitat, however, GCU has indicated that they will 

decommission old drill/exploration trails throughout their property. This will reduce the overall 

cumulative km's of linear corridors in this area. 

3. The analysis of the potential effects to moose, caribou and fur bearers presented throughout 

the ESR is sufficient for a Class C EA. 

4. The corridor will remove 0.654 km2 of forest, 0.33 km2 of which is already approved for clearing 

in the Trout Forest FMP. 

5. Work of this nature is commonplace in Ontario and the impact mitigation measures are well 

established in the guidance documents referenced in the final ESR. GCU will adhere to these 

guidance documents. 

6. GCU is proposing more expensive clear span bridges for the crossings at Birch River and 

Deaddog Creek to avoid work in the water and avoid disturbance of fish spawning habitat. 




Page 14 

1. GCU has adopted measures to limit access and reduce impacts of the road, including installation 

of gates, maximizing setbacks, and signage restricting access. 

2. Speed limits on the road will be necessarily low, because of the standard to which it is being 

constructed. 

3. Local Aboriginal communities were asked to provide information on how the project will impact 

their Aboriginal and Treaty rights. To date no specific issues have been raised by any of the 

communities. 

4. TFTO’s assertions are not substantiated. Information used throughout the document to support 

TFTO’s position is either incorrect or taken out of context of the ESR. For example, the concerns 

that have been raised by various stakeholders (in general sense) are accurately stated, but the 

mitigation measures that have been adopted to address the concerns are completely 

disregarded by TFTO 

5. GCU is prepared to adopt a good neighbour policy. A TFTO member proposed to write a draft 

policy for discussion, but did not follow through. GCU last offered to discuss moving this 

forward on the conference calls with the TFTO on January 21 and February 4, but TFTO has not 

responded. 




Page 15 

1. GCU is open to developing such a policy, but does not see this good faith commitment as a 

condition precedent to conclude the Class EA process. 




Page 16 

1. General Comment on Section 5: The 2011 reports are DRAFT and were intended to be used in 

conjunction with successive years of data for future project permitting. The data for these 

reports was not collected for the purposes of the access corridor, but some of the data collected 

in these reports was useful when viewed relative to the 2012 data. It appears TFTO has only 

reviewed the 2011 environmental baseline reports and did not take the report in Appendix 4 

(Biological Constraints Report) into consideration in their comments. At the time of data 

collection for the 2011 reports, no access corridor was being proposed, therefore, the data 

collected was to support anticipated general environmental permitting for exploration. The data 

collected in 2011 is relevant to the corridor in that the work completed characterizes the 

general biodiversity and ecology of the area. The work conducted in 2012 covered a much wider 

study area, and encompassed both potential access corridors and the exploration camp area. 

Various study areas were also developed for the areas surrounding the corridors and camp, the 

size of which varies depending on the parameter being studied (vegetation, wildlife, etc.). These 

study areas are explained and presented in the report found in Appendix 4. 

2. It is standard for ESR's to reference methodologies and provide brief descriptions. Providing 

complete methodologies in full detail is beyond the scope of an ESR, provided the 

methodologies are clearly referenced. Having only reviewed the 2011 baseline reports, it is not 

surprising that TFTO has concluded the studies were deficient in some aspects. However, a full 

review of the Biological Constraints Report in Appendix 4 demonstrates a thorough and 

appropriate analysis was completed. 

3. GCU hosted Open Houses for each of CLFN, SFFN, and LSFN in their communities in mid-May, 

prior to the start of the 2012 field program. GCU also hired FN technicians to actively participate 

in the studies. These technicians were valuable members of the survey teams, applying their 

local knowledge to the studies to ensure good quality results were obtained. 

In the case of the archaeological studies, GCU hired 2 FN workers who had led or participated in 

their recent LUP Aboriginal Traditional Knowledge study and were therefore well versed in the 

Traditional Knowledge of the area. Another worker had local knowledge of the area, and 

previous experience on other archaeological studies. GCU has made best efforts to incorporate 

as much Traditional Knowledge into the baseline studies as the Aboriginal communities have 

been willing to share. 

4. This is taken out of context. The ESR report clearly qualifies that the numbers provided are 

based on benchmarking of other similar mines and that the actual characteristics of future mine 

production would be defined in the PEA, see page 4, ESR. 




Page 17 

1. The economic information was included to provide context and justification for the proposed 

Project, which is a necessary means (exploration) to achieve a desirable end (a mine) that is 

being promoted by the province. Years of exploration work have finally advanced the 

exploration project to the point where a substantial mineral deposit has been outlined with 

potential to progress to a developed mine. To advance that project in a timely manner, GCU 

requires better access to the property. The scale of the Springpole Gold Project is an integral 

factor in the justification for the improved access. 

2. The project has advanced to a stage such that, for continued evaluation of the mineral deposit 

to be completed in a timely manner, a road is required. 

3. GCU and MNR advised that comments related to the future mine development were outside the 

scope of this EA and would be addressed in a future mine development EA, when GCU is in a 

position to advance the mine development permitting. The distinction between exploration 

activities, mine development activities and the proposed Project has been ignored throughout 

the TFTO Submission. 

4. The general public is welcome to comment on GCU's exploration activities through the Ministry 

of Northern Development and Mines, who have oversight for the exploration and mining 

activities. 

5. It was an oversight that the total length of the road is not stated in the report. The corridor 

width is stated many times (pages vii, viii, xii, 5, 31(item 4), and 44). The baseline study areas 

are defined in Appendix 4, page 9, and Fig 1-2. 

The exact locations of field work for the 2011 reports is indicated within each of the 2011 

baseline reports, and the TFTO make reference to the locations of this work in their Submission. 

The locations of the data collection efforts post-2011 can be found in the Biological Constraints 

Report in Appendix 4 of the ESR. 

6. Refer to Project Description, page xii, Appendix 4, pages 11-12 

The exact size and location of the various study areas can be found in the Biological Constraints 

Report in Appendix 4 of the ESR (Page 9 "Assessment Boundaries" and Figure 1.2 Regional and 

Local Study Areas in the Springpole Lake Area, page 10) 

7. The exact size and location of the various study areas can be found in the Biological Constraints 


Local Study Areas in the Springpole Lake Area, page 10). 




8. Please see Section 5.2, page 46 of ESR. 

9. This is not a requirement for a category C Class EA. GCU's primary use of the road would be 

during winter months, when traffic volumes are low. The speed at which vehicles will travel will 

be necessarily slow due road conditions and standards. This will minimize safety issues and the 

risk of wildlife strikes. 




Page 18 

1. This is not a requirement of a Category C Class EA. 

2. The naming convention for the study areas will differ between reports, but should be consistent 

throughout each individual report. It is common practice to have study areas that differ 

depending on which environmental parameter is being investigated, however, all of the various 

study areas will fall into one overriding study area. This hasn't necessarily been clearly laid out 

as these reports are DRAFT and are meant to eventually be compiled for future permitting 

purposes. 

3. GCU disagrees with the assertion that the maps provided in the reports are of poor quality and 

low resolution. Figures are exported at 700 dpi, which is a high resolution for a report figure. To 

date the ESR report has been distributed to various provincial as well as federal agencies. The 

figures presented in the report met the criteria established by these agencies. The baseline 

reports have also been distributed and no comments regarding the quality of the figures have 

been received. 

4. The aerial survey conducted in 2011 covered 81 km 2 . This aerial survey covered only GCU land 

claims at that time. Since then, an additional aerial survey has been conducted which covered 

approximately 900 km 2 (see ESR appendix 5 "Field report from DST") 

5. The exact locations of field work for the 2011 reports is indicated within each of the 2011 

baseline reports and TFTO makes reference to the locations of this work in its Submission. The 

locations of the data collection efforts post-2011 can be found in the Biological Constraints 

Report in Appendix 4 of the ESR 

6. The exact size and location of the various study areas can be found in the Biological Constraints 


Local Study Areas in the Springpole Lake Area, page 10) 

7. See previous comment (#6) 

8. Recommendation is based on incorrect information. 




Page 19 

1. The corridor width stated in several places in the ESR (pages vii, viii, xii, 5, 31(item 4), and 44). 

The corridor length is not stated in the body of the ESR report. This was an oversight. 

2. Area to be cleared for the entire 43 km corridor of the proposed Project is only 0.645 km2 NOT 

645 km2, as stated by the TFTO. Number is based on incorrect calculation of the corridor. 

(43km x 0.015 km = 0.645 km). This includes 0.33 km 2 which is already approved for clearing in 

the 2009-2019 Trout Lake FMP, so only 0.315 km 2 is proposed for additional clearing as part of 

the GCU Project 

3. The buffer zone used to analyze the impacts to large fur bearers and caribou was not 500 m, as 

stated in the TFTO Submission, it was 25 km on each side of both proposed corridors and the 

exploration area (ESR Appendix 4 - page 9 of the Biological Constraints Report) 

4. As explained in the ESR Appendix 4 - page 9 of the Biological Constraints Report, the dimensions 

of the buffer zones are based on the area believed to be impacted by construction of the 

corridor on any given environmental component. These buffers were developed by an 

experienced wildlife biologist with first-hand knowledge of the area and through the review of 

other studies. These areas were also agreed upon by members of the Ontario Ministry of 

Natural Resources prior to submission of the ESR. 

5. The terrestrial baseline studies were not "intended to assess a limited area". The 2011 

assessments were intended to be used in conjunction with successive years of data for eventual 

environmental permitting for the mine. Some of this information was used in addition to 

extensive terrestrial field data from 2012 which covered a much larger area, and does reflect 

true environmental conditions. 

6. The abundance of wildlife documented in and around camp is actually quite high and includes 

many species of birds, as well as bats, caribou, bears, wolves, marten, fox, wolverine, rabbits, 

and small mammals, to name a few. It is our opinion that the GCU camp has had a negligible 

effect on the results of wildlife studies, as indicated by the fact that the 2012 studies conducted 

across a much larger area, yielded very similar results to those conducted in and around the 

camp. 

7. All studies followed acceptable scientific methodologies, and these methodologies are 

referenced where applicable. Statistical analyses for many of the parameters studied are not 

necessary. Baseline data collection is not a research undertaking, it is completed to fulfill the 

permitting process. Again, the TFTO appears to be referencing only the 2011 baseline studies 




(which were not intended to describe conditions at the proposed access corridor) instead of the 

material presented in Appendix 4 of the ESR. 

8. The databases used were the most complete and up to date data sources available. The 

consultation of these databases is a mandatory and commonplace task undertaken with all 

baseline studies. 




Page 20 

1. See previous comments in regard to page 16 of the TFTO Submission stating the importance of 

2011 work being viewed in conjunction with 2012 work. Amphibian call counts were conducted 

in 2012. 

2. This statement is incorrect. Please review ESR Appendix 5. In addition to conducting two aerial 

surveys in two years, a very detailed habitat analysis was completed using the Ontario 

Landscape Tool (OLT) developed by the OMNR. This is significantly more work than that 

undertaken by the OMNR to develop moose management guidelines for wildlife management 

units. The OMNR conducts moose aerial inventories every 3 years (sometimes as infrequently as 

5 or 7 years in northern units) and flies only a small, representative portion of the wildlife 

management unit. They currently do not use the OLT to assist in setting management guidelines. 




Page 21 

1. Note that the OLT developed PREDICTED moose densities over large spatial scales. "Low 

densities" is a subjective term and represents moose densities of between 0 and 0.17/km2, 

compared to more southern areas of the boreal forest with "high" moose densities in the 0.22 

to >0.30 range. The terms associated with these densities are a default density set by the OLT. 

2. Our approach to developing estimates and inferences regarding moose densities was not flawed 

and involved a more holistic approach than the provincial government uses to determine tag 

allocations for wildlife management units throughout Ontario. 

3. The study was discussed many times with the OMNR in order to ensure that data collection 

efforts were relevant. GCU also conducted open house sessions with FN groups (See Section 3-1- 

4, ESR) to discuss the planned studies and to receive feedback on every aspect of our baseline 

data collection efforts. 

4. Moose densities for the area were determined through OLT modeling (predicted moose 

densities) as well as through the mapping of late winter moose habitat (Figure 2.15, pg. 39 of 

ESR appendix 4 Biological Constraints Report) 

5. Multiple aerial surveys were conducted over the area (2011, 2012). Aerial surveys for ungulates 

are not conducted outside of winter because they are very difficult to see with no snow cover 

and with leaves on the trees. 

6. Calving and feeding area data was obtained from the Red Lake OMNR. Caribou calving surveys 

were completed throughout the study area and on potential lakes adjacent to the eastern 

corridor (ESR, appendix 4, Biological Constraints Report, pg. 72) 

7. It is beyond the scope of a Class C EA to determine moose populations. We presented moose 

densities in a 900 km2 study area and modeled predicted moose densities for the regional study 

area. 

8. The concept of range can be interpreted in many ways. It can mean the amount and 

arrangement of summer and winter habitat, and it can relate to seasonal food abundance, 

calving areas, mineral licks, and aquatic feeding areas, as well as other aspects. The ESR, 

Appendix 4 Biological Constraints Report touched on the more important aspects of moose 

range including later winter habitat (considered one of the most limiting factors to moose 

populations) and identified known aquatic feeding areas and calving areas. The ESR also 

addressed what the impacts (if any) would be to those resources through the construction of 

the road (pages 37, 39, 43, and 58-60). 




9. The potential effects of predation and hunting (with a focus on caribou) is presented throughout 

the ESR, appendix 4 Biological Constraints Report. 

10. First Nation members assisted with all of our field activities and open house sessions were 

conducted to solicit input on all studies. They provided very valuable input and were an integral 

component of the success of GCU field programs. 




Page 22 

1. The statement that caribou data was based solely on literature reviews and modeling without 

on-site observations is incorrect. Two aerials surveys were conducted, caribou calving surveys 

were completed, trail cameras were deployed throughout the study area, and all caribou 

observations were recorded. The combination of literature review and the collection of field 

data cannot be considered "armchair effort" as suggested by the TFTO. These efforts required 

hundreds of hours of field time. This data is presented in the ESR in Appendix 4, Biological 

Constraints Report pg. 62-83 and in Appendix 5. 

2. The statement that "the granting of a harvesting permit, prematurely, will only serve to push 

this animal into the extinct category" is inflammatory. Access corridors can be detrimental to 

caribou populations through the facilitation of predation. However, roads are frequently built in 

caribou habitat for forest management purposes, and with sufficient planning and mitigation, 

the two can coexist. 

3. The caribou cumulative effects assessment screening report cannot be made available to the 

public due to the fact that it contains sensitive information such as the locations of caribou and 

caribou calving areas. All of the relevant data from this report was included in the ESR, Appendix 

4, Biological Constraints Report. 



April 2013 Schedule 2/- 24-

Page 23 

1. This statement is incorrect. Please review ESR Appendix 5. In addition to conducting two aerial 

surveys in two years, DST also received caribou collar data from the OMNR from 1998 - 2012. All 

of this data was used in the woodland caribou analysis in the ESR, Appendix 4 Biological 

Constraints Report pg. 61-65. 

In addition to DST baseline studies, GCU also provided logistical support and a FN helper to 

assist the MNR in a caribou calving study conducted in the area during the 2012 field season. 

2. Incorrect, please see the ESR, Appendix 5 

3. Incorrect, please see the ESR, Appendix 5. 

4. Please see comment #5 below. 

5. The caribou cumulative effects assessment screening report took all of this information into 

consideration with the exception of food sources. Food has been found not to be a limiting 

factor for caribou except under extreme conditions such as those found on the Slate Islands. 

6. A First Nations member assisted with all of the caribou field work, including the aerial surveys. 

Open House sessions were conducted with local FN communities, at which participants were 

asked to provide information on caribou and caribou habitat, as well as other biological factors 

prior to the 2012 aerial survey and prior to the calving surveys. 

7. The ESR and the Technical reports do not "state that insufficient data was available on woodland 

caribou to make any conclusions about the herd." This is an interpretation of the TFTO. No 

conclusions about the caribou herd were made in the ESR or the Technical reports. The ESR and 

the technical reports provide data which concludes that the potential negative effects through 

the construction of an access corridor can be mitigated. The authors of the ESR and the 

Technical reports feel that the data supporting these conclusions is sufficient. 

8. TFTO’s Recommendation is based on incorrect assumptions and information. 

9. This statement is incorrect. Large mammals were assessed through two aerial surveys. They 

were also assessed through the deployment of trail cameras throughout the study area. All of 

the large mammals and furbearers mentioned in this paragraph are not species at risk, are 

common throughout the study area and the boreal forest, and their habitat and ecology are well 

understood, therefore a specific detailed study is beyond the scope of a Class C EA. 




Page 24 

1. General comment on 5.3.2: Small mammal trapping followed the OMNR small mammal 

trapping methodology, which is standard practice in Ontario. The area trapped in the 2011 

report was completed as general baseline data collection for future mine permitting, not 

specifically for the access corridor EA. Small mammal trapping occurred in 2012 with 136 traps 

being spread out over a much larger area. There are no small mammal species at risk, and the 

species captured during both trapping sessions (2011 and 2012) were all common to the boreal 

forest, therefore conducting a specific detailed study of small mammals is beyond the scope of a 

Class C EA. 




Page 25 

1. Point count locations were randomly located in specific habitat types throughout the area being 

studied in 2011. The 2011 study area did not include the potential access corridor. 

2. The squares 15WS48, 15WS49, 15SW58 and 15SW59 can be added to the figure, but they would 

contain no values, because these blocks contain no relevant data. 

3. The fact that some OBBA blocks did not have any data, does not mean the desktop study was 

"incomplete and not relevant". The data used was the most up to date data available. The 

background research would have been incomplete if the OBBA had not been referenced. 




Page 26 

1. The background database information used made no reference to species abundance, it was 

consulted as standard practice for data collection efforts. 

2. Two sessions of breeding bird point counts were conducted in 2012 with 37 point count 

locations covering a much larger area than the 2011 surveys. 

3. The locations chosen for the 2011 breeding bird surveys were appropriate for our understanding 

of the Project at that time. Providing brief summaries of methodologies along with a reference is 

standard practice in technical writing for these types of reports. The methodology as written in 

1997 by Konze and McLaren is standard practice and has been validated by others. 

4. There are many protocols for conducting breeding bird surveys. The Environment Canada 

protocol mentioned by TFTO is not applicable because of the terrain. While conducting breeding 

bird surveys, it is most important to cover the available habitat types in the area, which is what 

was done in 2012. Detailed statistical analyses of the 2012 data was completed using the 

Environment Canada protocols and methodologies. 

5. Section 5.3.2 General Comment: Through discussions with the species at risk biologist for the 

Red Lake area, it was determined that the study area location was outside known Whip-poorwill 

range and possessed no Whip-poor-will habitat. Also, because there are no roads in the 

area, it was considered a health and safety risk to conduct standard whip-poor-will surveys 

because they are done at night and would have required extensive walking through the bush. 

Whip-poor-will are known to set up territories within close proximity to human settlements, 

particularly where areas have been cleared and gravel has been applied. Therefore, if these 

birds were in the area, they would most likely occur in close proximity to the camp. 




Page 28 

1. Nowhere in the ESR or Appendix 4, Biological Constraints Report, does GCU make the 

assumption that any species does not exist in this area. Rather, the report notes that no 

individuals of certain species were encountered. 

2. TFTO insinuates that the entire length of the access corridor (which is incorrectly given as 645 

km2) is comprised of old growth forest. The total area of old growth forest within the entire 

potential access corridor is 0.05 km 2 . 

3. The FRI used for this study was produced in 2000. This does not make the ecosite information 

within the FRI out of date, as ecosites do not change through time due to the fact that they are a 

result of topography, and soil type. 

4. The Ontario species at risk list was consulted prior to conducting field assessments. There are no 

Ontario vascular plant species at risk with a range overlapping the study area. 




Page 29 

1. Comments on Table 3: The information shown in Table 3 shows the species at risk in the 

province of Ontario, which includes species that may or may not be found in Northern Ontario. 

Based on a desktop review of the list of species at risk, and a conversation with the Red Lake 

OMNR species at risk biologist, none of these species have the potential to occur in the study 

area. 




Page 30 

1. The locations chosen for the 2011 vegetation surveys were appropriate for our understanding of 

the Project at that time. 

2. All species encountered during field work were documented. The species list from the 2011 

vegetative survey can be found in Appendix A of the 2011 Terrestrial report. None of the species 

at risk listed in Table 3 of the TFTO Submission occurred in any of the vegetation plots. 

3. This goes beyond the requirements of a Class C EA. 

4. There is extensive discussion on potential impact to the terrestrial environment including 

vegetation in the ESR Appendix 4, Biological Constraints Report. 

5. No vascular species at risk were found to occur within our study area. 

6. No vascular species at risk were found to occur within our study area. 

7. This is not normally a component of a Class C EA. 

8. Statistical analysis of vegetation is beyond the scope of a Class EA. 

9. These recommendations would go far beyond the requirements for this type of road project. 

The information included in the ESR Appendix 4, Biological Constraints Report is sufficient and 

the TFTO recommendations are based on an incomplete understanding of the information 

already available and incorporated in the ESR. 




Page 31 

1. Water quality at Springpole is not related to the ESR for the access corridor. TFTO also appears 

to condemn all mining activities. Significant effort is made to monitor water quality. To 

determine if drilling activities at Springpole have an effect on surface water, water quality for 

one lake not affected by the project (reference lake) and one lake located downstream from 

Springpole Lake were also included in the Aquatics Baseline Report. A comparison of water 

quality in a Lake not directly affected by exploration activities will serve two purposes: to collect 

data that will serve as a benchmark to be referred to when mining activities start and to 

determine if abiotic changes have any influence in the general conditions of the area. After 

careful examination of the data, there is no evidence that Springpole Lake has been affected by 

drilling activities. This is based on water quality data collected at different sampling locations 

and at different sampling times, that totals 27 samples collected in Springpole Lake. Of these 27 

samples collected, one sample had an exceedance in cadmium. That cannot be considered as a 

reflection of the water quality in the whole Lake. 

2. The statement in bold is a lead in to the underlined statement on page 32, which is based on a 

quoted reference document that does not support the TFTO’s conclusions about contamination 

of water from drilling activities. See comments in regard to page 32 of the TFTO Submission. 

3. Total phosphorus: Five samples had elevated concentrations of phosphorus. One sample was 

collected in Springpole Lake, one sample was collected at the unnamed pond (west of the 

Springpole camp), one sample was collected in Birch Lake, and two samples were collected in 

Seagrave Lake. To state that phosphorus was elevated in the study area would be a 

misinterpretation of the results. The lakes studied had more than one sample collected during 

2011 and therefore an exceedance in one water sample cannot define the overall conditions in 

the whole lake. Moreover, the lake that had more exceedances in phosphorus was Seagrave 

Lake, which is located upstream from Springpole Lake. 

4. Elevated dissolved mercury concentrations were found in three samples. Sample SW3, located 

in Birch Lake had elevated mercury concentrations during the winter sampling event. Two 

samples had elevated concentrations of mercury in Seagrave Lake at sampling site SW5. No 

samples had elevated mercury concentrations in Springpole Lake, where drilling activities have 

been conducted. It should also be noted that Seagrave Lake is located upstream from 

Springpole Lake, and therefore drilling activities at Springpole Lake would not influence water 

quality at Seagrave Lake. As for the sample collected at Birch Lake, similar to the one cadmium 

exceedance, statistically this result could be an outlier. Based on the results of the surface 

water quality sampling, it was recommended to continue the monitoring of surface water 

quality to determine if the elevated mercury observed at SW3 is an outlier or a reflection of 

mercury contamination. 




5. Elevated cadmium concentrations were found during the winter sampling event at one sampling 

location (SW-11), located within Springpole Lake. Only one sample at one sampling period 

showed exceedances in cadmium when compared to the provincial water quality objectives. 

One sample at one sampling period does not represent the conditions of a lake. Samples were 

collected in more than one sampling location within Springpole Lake. Samples were also 

collected quarterly, and therefore to describe the lake chemistry it would be necessary to 

statistically analyze all samples collected. It is likely that the sample collected at SW-11 and 

analyzed for cadmium is an outlier. An outlier is an observation that appears to deviate 

markedly from the observations in the sample. Outliers may be due to random variation. 

Outliers are not typically removed from data sets as they may point to a trend in the 

characteristic of the surface water quality. Once an outlier is identified, the recommendation is 

always to continue monitoring to determine if these value is an indication of a trend or just a 

result of natural variation. 

6. Elevated total Iron concentrations were found during the summer sampling event at two 

sampling sites. One sampling site (SW-9) was located in the unnamed pond located west of the 

project camp, while the second sampling site (SW10) was located in Seagrave Lake. These are 

two samples in two different lakes that cannot be used to described conditions at the Springpole 

Lake where drilling and advanced exploration activities are underway. As mentioned before, 

Seagrave Lake is located upstream from Springpole Lake and therefore is not being affected by 

the project, as contaminants do not travel against the water gradient. Statistically, the influence 

of these samples in the overall water quality at those particular lakes will be very small. The 

recommendation in the Aquatics Baseline report was to continue sampling surface water to 

better understand the dynamics of these elements in the surface water at all three lakes studies 

and the unnamed pond. Water sampling is ongoing. 

7. Refer to figure 2.1 located in page 14 of the Aquatics Baseline report for a figure showing all 

water quality sampling locations. 

8. It is not scientifically defensible to say that based on one or two samples, a lake has elevated 

concentrations of any particular parameter. The idea behind a baseline study is to collect 

multiyear data to identify the normal range of different parameters in a particular lake. The 

2011 Aquatics report represent the first cycle of sampling at Springpole Lake, Birch Lake and 

Seagrave Lake, the second cycle has been completed and a third cycle is being planned. The 

data collected during the three cycles will provide with statistically and scientifically defensible 

data that will show baseline conditions of these lakes. 




9. The aquatics baseline report does not address in any way the ESR, and to draw conclusions 

about the effects of the ESR for the access corridor based on the aquatics baseline report is not 

appropriate. 




Page 32 

1. With the exception of one sample at one sampling event that exceeded cadmium when 

concentrations were compared to PWQO, no heavy metals, or metals in general, exceeded 

PWQO values in Springpole Lake. Mercury exceedances were observed in three samples; one 

sample from Birch Lake and two samples taken during two different sampling periods in 

Seagrave Lake. Iron concentrations were found to be elevated at one sampling location in the 

unnamed pond located west of the project camp and at one sampling location located in 

Seagrave Lake. Evidence of heavy metals would be found routinely in Springpole Lake if drilling 

were indeed releasing heavy metals onto surface water. Drilling activities in Springpole Lake 

cannot affect an up-gradient Lake, as metal movement through a water system does not flow 

up-gradient. Birch Lake is located up-gradient from Springpole Lake. Given the size of 

Springpole Lake and the distance between the location of the drilling activities and the location 

where the sample with high mercury was collected, a gradient of mercury concentrations should 

be observed and not just one sample located a very long distance from the drilling activities. 

2. Results for the toxicity testing at Springpole Lake are not required for the road corridor 

activities. The collection of water samples for toxicity testing was to gather a baseline result 

that can be then used as a benchmark for mine activities under the metal mining effluent 

regulations (MMER). It should also be noted that a pass/fail is the first step in environmental 

sciences to determine if water has potential for toxicity. Springpole Lake is considered a pristine 

Lake, and therefore it was expected that conditions at this lake are capable of supporting a 

healthy aquatic ecosystem. The aquatics report should be read in conjunction with the fisheries 

report that shows that Springpole Lake has a healthy population of fish, with walleye capable of 

living up to 18 years and reaching lengths of 58 cm. Toxicity testing for the purposes of 

industrial effluents or receiving waters need to follow methodology approved by Environment 

Canada (http://www.ec.gc.ca/faunescience-wildlifescience/default.asp?lang=En&n=0BB80E7B- 

1). Moreover, the toxicity testing suggested by TFTO are used for testing of individual chemicals 

for human use or for human exposure. These studies are usually conducted by: 1) the study and 

observation of people during normal use of a substance or from accidental exposure, 2) 

experimentally, by exposing animals to specific compounds and 3) experimentally using cell 

cultures, that could be human, animal or plant derived. For fish and invertebrates there are no 

approved methodology that can be used to evaluate toxicity in their environment, unless there 

is a clear chemical of concern. The results of the water sampling at Springpole Lake shows that 

one sample in the whole lake had an exceedance in cadmium. For this element to be considered 

for further toxicity testing, cadmium concentrations should be demonstrate to be high in more 

than just on sample and at one time point. 

3. As mentioned in the response for Page 32, Comment 2, the results of the limited toxicity testing 

will be used as a benchmark result to compare toxicity data collected once mining activities 

result in the production and release of effluent. Effluent as well as the receiving waters will be 




assessed through toxicity testing as defined in the metal mining effluent regulations (MMER). 

Moreover, there is sufficient evidence in the fish studies showing that the fish living in 

Springpole Lake are healthy and that the lake is capable of supporting a healthy fish population. 

4. It is not clear what TFTO means with this comment. The Aquatics Baseline Report shows the 

surface water and sediment quality, as well as the benthic invertebrate community composition. 

The baseline report pointed out exceedances in water quality that are above PWQO, and 

recommends further study of water quality to determine trends in chemical composition, that 

would point to specific characteristic of that body of water. Baseline studies usually gather 

multi-year information as one year may not reflect the normal chemistry of a body of water. 

The 2011 Aquatics report shows water characteristics in one year and therefore assumptions 

into water quality need to be considered carefully, understanding that to gain an in depth 

knowledge of water quality more data is needed. TFTO’s criticism of the methodologies is 

unwarranted. The methodology used for the collection of samples (water, sediment and 

benthics) are those approved by government agencies. The second cycle of surface water, 

sediment and benthics data has occurred, and preparations into the collection of a third cycle 

are underway. Taken together these three cycles of sampling will provided a much better 

overview of the water quality characteristics at Springpole Lake. 

5. The Aquatics Baseline report does not deal with or intend to give any information pertaining to 

the ESR. 




Page 33 

1. Table 4 General Comment: Road construction work is well understood and mitigation measures 

are proven and committed to in the final ESR to mitigate items listed in TFTO’s Table 4(see page 

89 of the ESR report). GCU will have a competent Registered Professional Forester, very well 

experienced in road building, to oversee all of the construction to ensure guidance documents 

are followed. This is articulated in the cover letter to the final ESR. 

2. GCU's Environmental Coordinator will monitor the water crossings on a monthly basis for the 

life of the road, to ensure functionality and physical stability, as well as ensure crossings are not 

creating sediment problems in the water or failing, ESR page 47. Section 8 of the final ESR 

describes the competent professional that will oversee construction and audit the road 

installation in accordance with well established guidelines. 




Page 34 

1. Life of this Project is only 2013 through 2017. As per Section 5.3 in the ESR, GCU has committed 

to decommissioning of the road by 2017, unless a Provincial EA has been initiated for the 

development of the deposit before that time. If that occurs, GCU will be proposing an upgraded 

access road as part of the mine development EA. 

2. Hydrogeology is the study of groundwater quality and movement, whereas hydrology is the 

study of surface water movement and distribution. Drilling was completed in accordance with 

proper exploration standard practices and a hydrology study was not required for drilling 

activity. 

3. Hydrology data collection was completed once a month, while surface water sample collection 

was completed quarterly. In the months where surface water and hydrology data collection 

coincided, both studies were done in conjunction. The TFTO also stated that "the aquatic study 

revealed that heavy metals were already elevated in Springpole". The concerns regarding heavy 

metals are thoroughly addressed in the comments in relation to TFTO pages 31 and 32, above. 

4. The Springpole project is currently at an exploration stage. All of the Activities such as dike 

construction, dewatering , open pit development, etc. outlined in the PEA will be subject to the 

mine development EA. They are outside the scope of the Class C EA for the access corridor. 

5. This is outside the scope of the Class C EA for the access corridor. Again TFTO has confused the 

work necessary for a mine development EA with the ESR Project, which is to improve access to 

the site to continue exploration activities. The Mine EA process is lengthy, generally taking at 

least 2-3 years to complete. In the ensuing time, GCU will continue to perform exploration 

activities to define the deposit at Springpole Lake, and better access to the site is an important 

factor to allow that to happen in a safe and efficient manner. 




Page 35 

1. General comment on Section 5.6: TFTO has misinterpreted the ESR. The ESR is stating that a 

road changes the landscape and that the MNR has admitted that they do not fully understand 

the implications of those changes. TFTO is also incorrect with regard to the sources used for the 

caribou data. Two aerial surveys were completed (2011 and 2012) and data was received from 

the MNR covering the dates of 1998-2012. Discussions regarding caribou are ongoing with the 

species at risk biologist from Red lake. 

2. Page number should be 53. 

3. General comment on Section 5.7: Monitoring plans will be developed in consultation with 

regulatory agencies and stakeholders once the EA is reviewed and approved. Stipulations and 

requirements will be tied to the permitting of the access corridor through the EA process. 

4. This type of project is common and proposed mitigation measures are well-established and 

proven over decades. 

5. GCU intends to have a long-term presence in the region and wishes to develop a working group 

to facilitate future discussions regarding the Springpole Gold Project. See page of the ESR 31, 

items 1, 7, and 8. 




Page 36 

1. These recommendations are more appropriate for the EA process for development of a mine. 

The ESR and the consultation and information sharing completed in preparing the ESR provides 

a strong foundation to approve the road corridor. GCU is committed to continuing to share 

information and consult with stakeholders and First Nations. 

2. Section 5.8 General Comment: GCU has addressed cumulative impacts within the ESR and 

Appendix 4 (Biological Constraints Report). Cumulative impacts were considered throughout the 

EA and GCU is proposing a road corridor that minimizes cumulative impacts. The nature and 

duration of the project are appropriate for a Class C EA, which does not require a formal 

cumulative impacts assessment. 




Page 37 

1. GCU has been transparent on this matter. GCU has discussed the potential for the road to be 

upgraded with First Nations and all stakeholders during consultation. GCU has consistently 

stated that if GCU, or another party, wishes to upgrade the road beyond what is proposed in this 

ESR, the upgrade will be subject to a separate EA. 

2. GCU is constructing the crossings to a primary road standard to be environmentally responsible 

by eliminating the need for any proponent (GCU or others) to replace the water crossings if an 

upgrade is ever carried out on the road. 

3. GCU modified the proposed Project from an originally contemplated all-weather access corridor 

to a gated seasonal winter road access corridor, as a mitigation measure to address comments 

received from TFTO stakeholders. GCU agreed to only construct a winter access road beyond 

the FMP approved portion of the road until such time as GCU could make a better 

determination as to proceed with a mine development. If GCU were to proceed with developing 

a mine, then GCU would upgrade the road to an all-weather access road. Review of that 

upgrade would be included in the EA process for the mine development. If the Springpole Gold 

Project did not proceed to mine development, then the winter access road beyond the FMP 

approved road could be decommissioned with better results than a fully developed gravel road. 

This plan is clearly described in Section 5 of the ESR. 

4. A 10-20 year plan cannot possibly be developed for an exploration project as exploration work is 

results driven, meaning future work programs are dependent entirely on the results of previous 

work. The Springpole Gold project is approaching a critical juncture in the next several years as 

to whether the project advances to production. At this point, there are still too many variables 

to predict the outcome, and hence no way to plan for 10 years in advance. This is typical of any 

mine development. 




Page 38 

1. Domtar has approval under their current FMP to construct a primary access road from Deaddog 

Creek to ~1 km south of the Birch River in the 2014-2019 period. The approval was granted in 

2009, over objections of the TFTO group. GCU has followed the same corridor to access their 

property, despite the additional travel distance, to avoid construction of a second access 

corridor in the area, thereby reducing the cumulative effects of industry in the area. 

2. New exploration permits can be obtained from MNDM at any time, and not all exploration 

activities require permits, so it is unlikely that Springpole activity will terminate in 2016, as TFTO 

has suggested. Nonetheless, the reference to GCU and Domtar using the road during the same 

period is actually looking at the long term potential road usage, and assuming a positive 

production decision. In that scenario, it is recognized that the north shore of Springpole Arm is a 

"B" forestry block, slated for harvesting during the 2019-2029 period. This could roughly 

coincide with the timing for Springpole production, should GCU reach a positive production 

decision. 

3. Domtar will be in a position to construct and use the FMP-approved section of the proposed 

road in 2014, according to the road use strategy approved in the Trout Forest Management 

Plan. North of the FMP-approved section, GCU will install a gate that will not allow access to 

any stakeholders, including Domtar, until such time as another EA is approved to grant access to 

others on that segment of the corridor. 

4. Absolutely no financial or administrative assistance has been provided to GCU from Domtar. 

Domtar has provided some valuable guidance on technical aspects of the corridor planning, 

particularly on the FMP-approved portion of the road. 

5. Section 5 of the ESR addresses road closure and decommissioning. 

6. GCU has nothing to do with Domtar harvesting plans. FMP maps showing harvesting schedules 

for the Trout Lake forest are available for public review annually and may be obtained from 

Domtar or the MNR. 

7. Domtar's use of the FMP-approved section of the corridor is governed by their FMP. Domtar 

will not be granted access to the northern portion of the corridor under this EA period. If/when 

they wish to gain access, they will have do so through an EA for their FMP. GCU will have a land 

use permit to have control of the road beyond the gate. 

8. Section 5.11 General Comment: GCU will rehabilitate the water crossings in accordance with 

long established MNR guidelines, as indicated in the final ESR. With respect to the rehabilitation 




of the corridor, GCU will re-forest it in accordance with the approved silvicultural prescriptions 

for the relevant stands in accordance with the Trout Lake Forest Management Plan. 

9. As clearly stated in Section 5.3 of the ESR, page 48, GCU would propose to decommission only 

the portion of the access corridor beyond the FMP-approved road. Domtar will be constructing 

a primary forestry access road between Deaddog Creek and 1 km south of the Birch River 

crossing, according to their approved FMP. They are responsible for maintenance and any 

subsequent decommissioning of their road, according to the approved FMP road use strategy. 

GCU has no responsibility or right to decommission a publicly funded forestry access road. 

Therefore, considering that GCU would decommission only the 21 km newly proposed access 

corridor, the area would be 21 km x 0.015 km = 0.315 km 2 not 645 km 2 . 

10. This is incorrect. 




Page 39 

1. This means simply that GCU will decommission the road, if the Springpole Gold Project does not 

proceed to production, unless another stakeholder steps up and requests that the road remain 

in place. If that were to happen, that party would have to submit an EA describing their planned 

use for the road and would take on the responsibility for the road, and if applicable, 

decommissioning according to their own road use strategy. 

2. This means that, should GCU proceed to develop the mine, rather than decommissioning the 

road in 2017, they will propose to upgrade the road to a primary access road as part of the mine 

development EA (a mine would require a more robust road than proposed in the ESR). Because 

the upgraded road would be part of the mine development plan, the decommissioning of the 

road would be included in the mine closure plan that would be completed by GCU. 

3. 0.315 km 2 . See comment 9, page 38. 

4. A mine closure plan, and the associated financial assurance, would address reclamation of all 

associated aspects of the mine development EA, including any necessary road decommissioning. 

5. Any required road decommissioning would be included in that amount. 

6. GCU has more than sufficient capital to decommission the 0.315 km 2 associated with a winter 

access corridor. Because this is a simple undertaking, with no gravel roadbed to be reclaimed, 

the reclamation would not be a costly undertaking. 

7. This is addressed in Section 5.3 of the final ESR, where GCU has indicated they will post a bond 

for decommissioning of the winter road beyond the approved FMP road, if the Springpole Gold 

Project does not proceed to a mine development. 




Pages 40, 41 

1. Section 5.12 General Comment: None of this is relevant as it does not relate to the Project 

being proposed in the ESR. The proposed Project is warranted for safety and economic reasons. 

If the Project is approved, as generally defined in the final ESR, GCU shall carry out the Project as 

defined in the final ESR and the approvals that are issued following the EA process. 




Page 42 

1. The recommendations from the TFTO Submission are addressed in the covering letter. 




APPENDIX 10 

SUMMARY OF POTENTIAL 

MEASURES TO ACHIEVE AN 

OVERALL BENEFIT TO WOODLAND 

CARIBOU

Supplemental Mitigation Measures for Potentially Significant Negative Residual Effects 

Potentially Significant 

Mitigation Measure* 

Negative Effect 

No impacts. No individuals detected on site, no habitat present except 

Eastern Whip-poor-will some potential habitat in 2011 burn area, in which case habitat is 

abundant 

Move road corridor 700 m away from calving lake (Dead Dog Lake) 

(subsection 9 and 10 of ESA) 

Reduced and/or eliminate traffic during calving period to reduce 

sensory disturbance by posting signage, educating staff on the 

importance of reducing speeds and reprimanding staff who violate 

Caribou calving 

restrictions (subsection 9 of ESA) 

Develop vegetation management plan with OMNR to manage early 

successional vegetation and keep alternate prey populations low to 

avoid proximate mortality to caribou (subsection 9 of ESA) 

Construct road outside of calving period (winter) (subsection 9 of ESA) 

Implementation Strategy 

N/A 

Integrate these mitigation measures 

into the Project execution plan 

(Section 5 of Final ESR). Continue to 

engage other parties regarding 

collaborations related to monitoring 

and habitat improvement. DST 

(2013A) provides further analysis and 

discussion. 

Caribou winter habitat 

Place corridor outside habitat or near edge of habitat where possible 


Utilize pre-existing drill trails where possible (subsection 10 of ESA) 

No plowing of road in winter when not in use to restrict predator travel 

(subsection 9 of ESA) 

Keep traffic volume to a minimum (subsection 10 of ESA) 

Reduce speed limits (subsection 9 of ESA) 








discussion.

Supplemental Mitigation Measures for Potentially Significant Negative Residual Effects 

Potentially Significant 

Negative Effect 

Mitigation Measure* 

Implementation Strategy 

Caribou and caribou 

habitat (general effects) 

Restore road to productive wildlife habitat upon closure where possible 


Decomission 8.6 km of historic exploration trails throughout GCU 

property to reduce total amount of linear features on the landscape 


Support the implementation of specific silvicultural practices in 

approved areas to improve and create caribou habitat (subsection 10 

of ESA) 

Avoid aggregate extraction activities within calving/nursery areas and 

winter habitat 

Pending guidance from MNR, install educational signage elsewhere 

within in the range (where there is public access) that is intended to 

help hunters distinguish between caribou and other ungulates 


Prohibit public access beyond the FMP Approved Road, focus usage 

during winter months, enforce 50 km/hr speed limit (subsection 9 of 

ESA) 

Minimize overall width of road wherever possible in order to reduce 

total linear feature size and area disturbed (subsection 10 of ESA) 








discussion. 

* includes whether the mitigation measure would avoid a prohibited activity under section 17 subsection 9 (species protection) or 10 

(habitat protection) of the Endangered Species Act ("ESA") 

Note: For additional detail on these impacts and mitigation measures please see Appendix 4 of Final ESR (Biological Constraints for 

Springpole Gold Access Corridor Project Alterntatives Assessment)

Revised Final Environmental Study Report (24 MB) - Gold Canyon ...

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