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Proposed HR Milner Expansion Project Environmental Impact Assessment Report Appendix 1C: Concordance Table for HR Milner Expansion Final Terms of Reference Maxim Power Corp. Page 1C-1 January 2009 Appendix 1C Concordance Table for HR Milner Expansion Final Terms of Reference

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Page 1: Appendix 1C Concordance Table for HR Milner Expansion Final … · 2016. 6. 17. · Proposed HR Milner Expansion Project Environmental Impact Assessment Report Appendix 1C: Concordance

Proposed HR Milner Expansion Project Environmental Impact Assessment Report

Appendix 1C: Concordance Table for HR Milner Expansion Final Terms of Reference

Maxim Power Corp. Page 1C-1 January 2009

Appendix 1C Concordance Table for HR MilnerExpansion Final Terms of Reference

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Appendix 1C: Concordance Table for HR Milner Expansion Final Terms of Reference

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1.0 Introduction

1.1 Background

[A] MAXIM Power Corp. (MAXIM or “the proponent”) is proposing todevelop a single unit, 500 megawatt (MW) coal-fired power plantreferred to as the HR Milner Expansion project (“Milner Expansion” orthe “Project”). The Project is located near Grande Cache, Alberta on thesite of the existing 150 MW HR Milner Generating Station. The legaldescription of the current and proposed operation is N1/2 of Section 10and the S1/2 of Section 15, Township 58 Range 8 West of the6

thMeridian which is situated in the Inner Foothills belt of the Rocky

Mountains, northwest of Edmonton. It is anticipated that the Projectwould be complete and operational by 2012.

[B] The Project will utilize much of the infrastructure of the existingHR Milner Generating Station. Water requirements will be met by theexisting water license. Alternative surface and groundwater sources willbe investigated. Ash from the plant will be disposed of at the existingFlood Creek disposal site until this site reaches capacity. Work willcommence to site a new ash disposal facility off-site. Information on theplanning of this new facility will be included in the EIA report; however,approval for the new facility is not part of the application.

[C] The purpose of this Terms of Reference is to identify for MAXIMand appropriate stakeholders the information required by governmentagencies for an Environmental Impact Assessment (EIA) reportprepared under the Environmental Protection and Enhancement Act(EPEA).

1.1 and 1.2

1.2 Scope

[A] MAXIM will prepare and submit an Environmental ImpactAssessment (EIA) report that examines the environmental and socio-economic effects of the construction, operation, and reclamation of theProject.

[B] The Study Area for the EIA report shall include the Project Area,as well as the spatial and temporal limits of individual environmentalcomponents outside the Project Area boundaries where an effect canbe reasonably expected. The EIA Study Area includes both Local andRegional Study Areas.

[C] The EIA report shall be prepared with consideration to allapplicable provincial and federal legislation, codes of practices,guidelines, standards and directives.

[D] The EIA report shall be prepared in accordance with these Termsof Reference and the environmental information requirementsprescribed under EPEA and associated regulations, and the CanadianEnvironmental Assessment Act, if applicable. The EIA report will formpart of MAXIM’s application to the Alberta Utilities Commission (AUC).An EIA report summary will also be included as part of the AUCApplication.

EIA report

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[E] The EIA report will include a glossary of terms and a list ofabbreviations to assist the reader in understanding the materialpresented. It will also include tables that cross-reference the report(subsections) to the EIA Terms of Reference.

Glossary andAppendix 1C

[F] The EIA report will include the key environmental issues that areimportant for the achievement of sustainable environmental andresource management. The report will also identify those issues thatwere raised during public consultation and differentiate betweenemerging issues (with ongoing uncertainties), issues with quantifiableand significant environmental effects, and issues which can be resolvedthrough available technology and with existing managementapproaches.

6.0

[G] MAXIM will prepare a summary of the EIA report that will providethe reader with sufficient information to obtain a general understandingof the Project and its potential positive and negative effects. Thesummary report must be a stand-alone document; however, it canreference more detailed information presented in the EIA report itself.

[H] The summary report should provide an overview of the EIA reportincluding:

a) the Project components and development activities whichhave the potential to affect the environment;

b) existing conditions in the Study Area, including existinguses of land, resources and other activities which havepotential in combination with proposed developmentactivities, to affect the environment;

c) the environmental, cultural, and socio-economic impacts ofthe Project including the regional, temporal, and cumulativeeffects which are anticipated;

d) impact significance in terms of magnitude, extent, duration,frequency, and reversibility;

e) proposed environmental protection plans, mitigationmeasures and monitoring;

f) residual effects;

g) an overview of modeling techniques used to forecastpotential effects and assumptions used in assessingpotential impacts; and

h) regulatory decisions that are needed for the Project toproceed.

Submitted asseparate stand-alone document

2.0 Public Engagement and Aboriginal Consultation

[A] Document the public engagement program implemented for theProject including:

a) documentation of individual participation and attendance ateach meeting, including recording of specific comments orissues raised at the meetings;

b) description and documentation of concerns and issuesexpressed by the public, MAXIM’s analysis of thoseconcerns and issues, and the actions taken to addressthose concerns and issues; and

3.0

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c) how public input was incorporated into the Projectdevelopment, impact mitigation and monitoring.

[B] Document the aboriginal consultation program implemented forthe Project including:

a) documentation of individual participation and attendance ateach meeting, including a record of specific comments orissues raised at the meetings;

b) description and documentation of concerns and issuesexpressed by aboriginal, the Proponent’s analysis of thoseconcerns and issues, and the actions taken to addressthose concerns and issues;

c) how aboriginal input was incorporated into the Projectdevelopment, impact mitigation and monitoring; and

d) consultation undertaken with aboriginal communities withrespect to traditional ecological knowledge and traditionaluse of land.

3.0

[C] Describe plans to maintain the public engagement and aboriginalconsultation process following completion of the EIA review to ensurethat the public and aboriginal peoples will have an appropriate forum forexpressing their views on the ongoing development, operation andreclamation of the Project.

3.0

3.0 Project Description

3.1 The Proponent

[A] Provide:

a) a corporate profile; and

b) the name of the legal entity that will develop, manage andoperate the Project and hold the operating approvals.

1.2

[B] Provide a brief history of the existing Milner Generating Station,coal-fired electricity generation in Alberta and development activities,resource characterization and environmental studies in the Project area.MAXIM shall provide an overview of Alberta’s deregulated electricalsupply system and discuss the need for additional electrical energycapacity and where and when the capacity is needed. MAXIM will alsodiscuss the proposed Project’s electricity supply capacity.

1.1 and 2.3.1

3.2 Project Development

[A] Provide a development plan that includes:

a) the phases of development;

2.2

b) coal processing and power generation facilities includingcoal handling, ash handling and disposal, and steam and/orpower generation;

c) infrastructure (pipelines, access roads and power lines);

d) other buildings and structures;

e) field maintenance operations; and

2.4

f) activities associated with development of the area,operations, reclamation and closure.

2.4

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[B] Provide a schedule outlining the proposed phases ofdevelopment and the sequence and duration of key projectcomponents, including the timing of key steps in the pre-construction,construction, operation, decommissioning, and reclamation stages ofeach phase.

2.2.2

[C] Provide information on mineable coal resources in the region(Grande Cache and area) to supply both the existing 150 MW HR MilnerGenerating Station and the proposed new unit for the expectedoperating life of the Project.

2.2.3

[D] Discuss the key factors controlling the schedule, restrictions forconducting certain development activities and uncertainties.

2.2.2

3.3 Evaluation of Alternatives

3.3.1 Project Alternatives

[A] Discuss the need for the Project addressing the following:

a) any alternative means of carrying out the Project that aretechnically and economically feasible and, whereapplicable, indicate their potential environmental effects andimpacts;

b) compare identified alternatives to the Project orcomponents of the Project and the anticipated effects andimpacts of the alternatives. Discuss reasons for notselecting any identified alternatives;

c) implications resulting from a delay in proceeding with theProject, or any phase of the Project; and

d) potential cooperative development opportunities for theProject (e.g. shared infrastructure).

[B] Discuss the implications of not going ahead with the Project.

2.3.1

3.3.2 Process and Infrastructure Alternatives

[A] Describe the process and criteria used to select sites for facilitiesand infrastructure.

2.3.2

[B] Discuss the route or site selection criteria for any linear or otherinfrastructure development or modification and provide the rationale forselecting the proposed alignment and design.

2.3.2

[C] Discuss how alternative technologies were evaluated andsummarize the results, including:

a) best available technology economically achievable (BATEA)for coal transport, coal processing, ash disposal, cooling,combustion, pre- and post-combustion treatment to removecontaminants including NOx (oxides of nitrogen), SO2

(sulphur dioxide), particulates, CO2, and mercury, CO2

reduction and potential capture and storage.

b) the environmental and energy thermal efficiency ofMAXIM’s selected generating technology compared toleading alternatives such as those outlined in the 1995 FuelCycle Emissions Analysis of Existing and Future ElectricGeneration Options in Alberta, Canada – IntegratedGasification Combined Cycle (IGCC), Pressurized Fluidized

2.3.2

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Bed Combustion (PFBC) and Coal/Natural Gas-FiredHybrids, providing:

i) a table comparing NOx, SO2, CO2, particulateemissions and energy efficiency; and

ii) a comparison of the effect of the technology on wastestreams, water requirements and disposalrequirements.

c) a comparison of the identified technology alternatives andtheir environmental effects, with the rationale for selectingthe proposed technology.

[D] Discuss the potential for new or additional technology to increaseenergy recovery during the life of the project.

2.3.2

[E] Describe the criteria and rationale for selecting the preferredwater supply sources. Include options for alternative surface watersources, off-stream storage and other criteria used to assess thefeasibility of its use.

2.3.2.6

[F] Discuss options and technologies considered for wastewatertreatment, wastewater management and wastewater disposal andreasons, including water quality and environmental considerations, forselecting the preferred options in the context of best managementpractices and best available technologies.

2.3.2.7 and 2.6.2.6

[G] Discuss the waste disposal options including coal ash disposaloptions. Discuss the strategy for on-site waste disposal versus off-sitewaste disposal and identify:

a) the location of on-site waste disposal including landfills, ifapplicable;

b) the availability of off-site waste disposals facilities;

c) site suitability from a groundwater protection perspective(provide geo-technical information to support the siting ofdisposal facilities); and

d) site suitability with regard to existing and potential humanactivities in the area.

2.3.2.8

3.4 Project Processes and Facilities

[A] Provide maps and/or drawings of the Project components andactivities, including:

a) existing infrastructure and facilities;

b) proposed infrastructure and facilities including coalhandling, ash handling and disposal, boiler, turbine andgenerator design, pollution control equipment and coolingsystems;

c) other buildings and infrastructure (pipelines and utilities);

d) temporary structures;

e) transportation and access routes including any new raillines and off-loading facilities;

f) on-site hydrocarbon storage;

g) containment structures such as berms and storage andretention ponds;

2.4.1

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h) water wells/intakes, pipelines, and storage structures;

i) sources of aggregate resources, borrow material and otherconstruction materials and locations of any stockpiles thatwill be developed; and

j) waste storage areas and disposal sites.

[B] Provide a list of facilities for which locations will be determinedlater.

N/A

[C] Discuss planned accommodations for the workforce during thelife of the Project.

2.4.12

[D] Describe the thermal recovery and other related processes andprocess facilities of the Project, and

a) discuss the amount and source of energy required for theProject; and

b) describe the proposed infrastructure to deliver thegenerated energy to market.

2.4.13

[E] Provide a listing of chemical products and catalysts to bemanufactured, processed or otherwise used for the Project, anddescribe, in general terms, how these products will be stored andmanaged. Identify products containing substances that are:

a) Canadian Environmental Protection Act (CEPA), 1999toxics;

b) listed on the National Pollutant Release Inventory (NPRI);

c) dangerous goods as defined by the federal Transportationof Dangerous Goods Act; and

d) on the Domestic Substances List and categorized asrequiring further assessment under Canada’s ChemicalManagement Plan.

2.4.14

[F] Describe the nature and amount of on-site hydrocarbon storage.Discuss containment and other environmental protection measures.

2.4.15

3.5 Transportation and Infrastructure

[A] Provide the results of consultation with Alberta Transportationand discussions with other industry operators.

2.5.2

[B] Provide a summary of any Traffic Impact Assessment carried outfor the Project, or where no Traffic Impact Assessment has beenprepared:

a) Describe the anticipated changes to traffic (e.g., type,volume) on highways during the life of the Project.Consider other existing and planned uses of the samehighways; and

b) Identify needs to upgrade existing roads, bridges, drainageand intersections (including Highway 40 infrastructure) orconstruct new roads.

2.5.3

[C] Describe and locate on maps the transportation infrastructurerequirements for the Project and how they relate to local communities.

2.5 and Appendix2B

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[D] Describe road access to and road development within the ProjectArea, and identify the type and location of road construction andreclamation materials, the volume of material needed and theavailability of these materials.

2.5.1, Appendix 2Band 2.11

[E] Indicate where Crown land dispositions may be needed for roadsor other infrastructure outside of the Project Area.

2.1 and Figure 2-1

[F] Describe crossings of watercourses or waterbodies required (withappropriate diagrams). Include:

a) timing;

b) construction standards or methods;

c) regulatory requirements; and

d) environmental protection plans.

N/A

3.6 Electric Transmission Infrastructure

[A] MAXIM shall:

a) discuss the capacity of the existing transmission lines in theGrande Cache area to handle the additional power whenthe proposed Project comes on-stream;

b) identify system upgrades that may be required to connectthe proposed Project to the provincial electrical grid;

c) provide results of discussions with the Alberta ElectricalSystem Operator regarding power additions to theprovincial electrical grid; and

d) identify the regulatory processes and decisions that willdetermine what changes to the transmission system arerequired to accommodate the proposed Project (e.g. theTransmission Regulation (AR 174/2004) under the ElectricUtilities Act, future applications under the Hydro and ElectricEnergy Act).

2.6

3.7 Land Management

[A] Provide a description and timing of land clearing activities. 2.7.1

[B] Provide a fire control plan highlighting:

a) measures taken to ensure continued access for firefightersto adjacent wildland areas;

b) forest fire prevention measures;

c) measures for determining the clearing width of power linerights-of-way; and

d) required mitigative measures for areas adjacent to theProject Area based on the FireSmart Wildfire AssessmentSystem.

2.7.2

3.8 Air Emissions Management

[A] Provide emission profiles (type, rate and source) for the Project’soperating emissions including point and non-point sources and fugitiveemissions, and for construction emissions. Consider normal, worstcase, upset, start-up and shut-down conditions. Discuss the following:

a) odorous or visible emissions from the proposed facilitiesincluding potential water vapour emissions from the

2.8

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proposed facilities with respect to drift, icing, fogging andvisibility;

b) annual and total greenhouse gas emissions for the life ofthe Project;

c) the Project’s contribution to total provincial and nationalgreenhouse gas emissions on an annual basis;

d) MAXIM’s overall greenhouse gas management plans;

2.8.5

e) the amount and nature of acidifying emissions, probabledeposition patterns and rates;

2.8

f) control technologies used to minimize air emissions such assulphur dioxide (SO2), carbon monoxide (CO), particulatematter (PMx), hydrogen sulphide (H2S), oxides of nitrogen(NOX), air toxics (including heavy metal emissions),polycyclic aromatic hydrocarbons (PAHs), selenium,mercury (e.g. fabric filters vs. particulate controltechnologies), arsenic, chromium, lead, radionuclideparameters, greenhouse gases, volatile organic compounds(VOC) and hazardous air pollutants from incompletecombustion;

2.4.6.1 and 2.8.8

g) fugitive emissions associated with the hauling and storageof coal;

2.8.2

h) ozone observations in the region, providing applicableobservational or modeling results from studies of emissionsources similar to the proposed Project and discuss howMAXIM will manage ozone regionally; and

7.1.3

i) fugitive emissions control technology to detect, measureand control emissions and odours from equipment leaks.

2.4.6, 2.8.2, 2.8.8,7.3.1.6

3.9 Water Resources

3.9.1 Water Supply

[A] Describe the water supply requirements for the Project, including:

a) the expected water balance during the life of the Projectand the proposed water source(s). Discuss assumptionsmade or methods chosen to arrive at the water balances;

b) the adjustment to water diversion activities to meet anyinstream flow objectives that may be set for the identifiedsources of supply;

c) the process, potable and non-potable water requirementsand sources for construction, start-up, normal andemergency operating situations, decommissioning andreclamation. Identify the volume of water to be withdrawnfrom each source, considering plans for wastewater reuse;

d) the variability in the amount of water required on an annualand seasonal basis as the Project is implemented;

e) the expected cumulative effects on water losses/gains dueto the Project operations;

f) potable water treatment systems for the life of the Project;

g) type and quantity of potable water treatment chemicals

2.9.1

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used; and

h) measures for ensuring efficient use of water, includingalternatives to reduce the consumption of non-saline watersuch as water use minimization, recycling, conservation,and technological improvements.

2.9.1.4

3.9.2 Surface Water Management

[A] Describe MAXIM’s surface water management strategy for theconstruction, operation, decommissioning and reclamation stages,including the following:

a) design factors considered, such as:

i) site drainage,

ii) run-on management,

iii) road run-off,

iv) erosion/sediment control,

v) slumping areas,

vi) groundwater protection,

vii) groundwater seepage,

viii) produced water management,

ix) flood protection, and

x) storage facilities;

2.9.2

b) permanent or temporary alterations or realignments ofwatercourses, wetlands and other waterbodies, includingregulatory and mitigation requirements.

2.9.1

[B] Describe realignments of Crown bed and shore and proposedcompensation.

N/A

3.9.3 Wastewater Management

[A] Describe MAXIM’s wastewater management strategy, including:

a) the source, quantity and composition of each wastewaterstream from existing and proposed facilities;

b) the proposed disposal locations and methods for eachwastewater stream;

c) design of facilities that will collect, treat, store and releasewastewater streams;

d) type and quantity of chemicals used in wastewatertreatment;

2.9.3

e) sewage treatment and disposal; and 2.9.3.2

f) the principles that have been incorporated into the Projectdesign for pollution prevention, waste minimization andrecycling.

2.8.8 and 2.10.2

3.10 Waste Management

[A] Characterize and quantify the anticipated dangerous goods, andhazardous, non-hazardous, and recyclable wastes generated by theProject, and:

a) describe the composition and volume of specific wastestreams and identify how each stream will be managed;

2.10

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b) describe how disposal sites and sumps will be constructed;and

c) describe plans for pollution prevention, waste minimization,recycling, and management to reduce waste quantities overthe life of the Project.

2.10.2

3.11 Conservation and Reclamation

[A] Provide a conceptual conservation and reclamation plan for theProject in the context of development on an existing brownfield site withconsideration to:

a) any existing Conservation and Reclamation Plan;

b) pre-development information with respect to land capability,vegetation, commercial forest land base by commercialismclass, forest productivity, recreation, wildlife, aquaticresources, aesthetics and land use resources;

c) integration of operations, decommissioning, reclamationplanning and reclamation activities. Discuss anticipatedtimeframes for completion of reclamation, including anoutline of the key milestone dates for reclamation and howprogress to achieve these targets will be measured;

d) discuss any constraints to reclamation such as timing ofactivities, availability of reclamation materials and influenceof natural processes and cycles;

e) post-development land capability with respect to:

i) self-sustaining topography, drainage and surfacewatercourses representative of the surrounding area,

ii) pre-development traditional use with consideration fortraditional vegetation and wildlife species in thereclaimed landscape,

iii) wetlands,

iv) self-sustaining vegetation communities representativeof the surrounding area, and

v) reforestation and forest productivity;

f) a revegetation plan for the disturbed terrestrial and aquaticareas, identifying the species types that will be used forseeding or planting, and the vegetation managementpractices to return disturbed areas to a state capable ofsupporting a self-sustaining vegetative community capableof ecological succession equivalent to pre-disturbanceconditions, considering factors such as biological capabilityand diversity and end land use objectives;

g) reclamation material salvage, storage areas and handlingprocedures;

h) reclamation material replacement indicating depth, volumeand type;

i) pre-development and final reclaimed site drainage plans;

j) integrating surface and near-surface drainage within theProject Area; and

k) promotion of biodiversity.

2.11

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[B] Provide:

a) a conceptual ecological land classification (ELC) map forthe post-reclamation landscape considering potential landuses and how the landscape and soils have been designedto accommodate future land use; and

2.11

b) a discussion of any uncertainties related to the conceptualreclamation plan.

2.11

3.12 Environmental Management Systems and Response Plans

[A] Summarize key elements of MAXIM’s existing or proposedenvironment, health and safety management system.

2.12.1

[B] Describe adaptive management plans that minimize the impact ofthe Project. Describe the flexibility built into the plant design and layoutto accommodate future modifications required by any change inenvironmental standards, limits and guidelines.

2.12.5

[C] Describe MAXIM’s emergency response system to minimizeadverse environmental effects, while protecting the safety of personnel,including

a) emergency reporting procedures for spill containment andmanagement, and

b) emergency response, public notification protocol and safetyprocedures.

2.12.6

[D] Describe MAXIM’s current and proposed source monitoringprograms with respect to the following:

a) air emissions, including fugitive emissions;

b) wastewater treatment and release; and

c) hazardous and non-hazardous waste treatment andstorage.

2.12.7

[E] Discuss how the results of monitoring programs and publiclyavailable monitoring information will be integrated with MAXIM’senvironmental management system.

2.12.3

3.13 Regional and Cooperative Initiatives

[A] Discuss MAXIM’s involvement in regional and cooperative effortsto address environmental and socio-economic issues associated withindustrial development, including:

a) potential cooperative ventures that MAXIM has initiated,could initiate or could develop with other industries andother resource users;

b) how MAXIM will work to develop and implement suchcooperative opportunities;

c) MAXIM’s participation in any regional forums;

d) how MAXIM would design and implement researchprograms where necessary; and

e) how regional environmental management initiatives will beincorporated into MAXIM’s management practices.

2.13

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[B] Discuss MAXIM’s regional monitoring activities including:

a) monitoring that will be undertaken to assist in managingenvironmental effects, confirm performance of mitigativemeasures and improve environmental protection strategies;

b) monitoring done independently by MAXIM;

c) monitoring performed in conjunction with otherstakeholders; and

d) new monitoring initiatives that may be required as a resultof the Project.

2.13

4.0 Environmental Assessment

4.1 Assessment Requirements

4.1.1 Scenarios

[A] Define assessment scenarios including:

a) a Baseline Case, which includes existing environmentalconditions and existing and approved Projects or activities;

b) an Application Case, which includes the Baseline Case withthe effects of the Project added; and

c) a Planned Development Case, which includes past, existingand anticipated future environmental conditions, existingand approved projects or activities plus other plannedprojects.

[B] For the purpose of defining the scenarios, “approved” meansapproved by any federal, provincial, or municipal regulatory authority;“planned” means any project or activity that has been publicly disclosedprior to the issuance of these Terms of Reference or up to six monthsprior to the submission of an Application and EIA report.

4.2

4.1.2 Study Areas

[A] The Project Area includes all lands subject to direct disturbancefrom the Project and associated infrastructure.

[B] The Local and Regional Study Areas include the Project Area andother areas based on individual environmental components where aneffect from the proposed development can reasonably be expected.

[C] The study area for the EIA report shall include the Project Areaand associated infrastructure as well as the spatial and temporalaspects of individual environmental components outside the ProjectArea boundaries where an effect can be reasonably expected. The EIAStudy Area includes both Local and Regional Study Areas.

[D] For the Project Area provide:

a) the legal land description;

b) the boundaries of MAXIM’s lease;

c) the proposed AUC approval area; and

d) a map that shows the status of land tenure and identifiesthe locations of all proposed development activities andfacilities.

[E] For the Local and Regional Study Areas provide:

a) a topographic map of appropriate scale showing the area

4.2

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proposed to be disturbed in relation to existing townshipgrids, wetlands, watercourses, and waterbodies; and

b) the scientific rational used to define the spatial and temporalaspects of the Study Areas.

4.1.3 Cumulative Effects Assessment

[A] MAXIM will conduct a cumulative environmental effectsassessment of the Project based on the EUB/AENV/NRCB InformationLetter Cumulative Effects Assessment in Environmental ImpactAssessment Reports under the Alberta Environmental Protection andEnhancement Act June 2000. MAXIM will include a summary of allproposed monitoring, research and other strategies or plans tominimize, mitigate and manage potential adverse effects.

[B] The identification and assessment of the likely cumulative effectsof the Project will:

a) define the spatial and temporal Study Area boundaries, andprovide the rationale for assumptions used to define thoseboundaries for each environmental component examined;

b) describe the current (baseline) state of the environment inthe regional Study Area (used for the cumulative effectsassessment) and the activities that have created the currentconditions;

c) assess the incremental consequences that are likely toresult from the Project in combination with other existing,approved and planned projects in the region;

d) discuss how relevant information or data used from otherdevelopment projects is appropriate for use in this EIAreport;

e) consider and describe deficiencies or limitations in theexisting database for relevant components of theenvironment; and

f) explain the approach and methods used to identify andassess cumulative impacts, including cooperativeopportunities and initiatives undertaken to further thecollective understanding of cumulative impacts, and providea record of relevant assumptions, confidence in data andanalysis to support conclusions.

4.3, 4.4, 7.4.3,8.4.3, 9.4.3, 10.4.3,11.4.3, 12.4.3,13.4.3, 14.4.3,15.4.3, 16.4.3,17.4.3, 18.4.3,19.4.3, 20.4.321.4.3

4.1.4 Information Requirements

[A] The EIA Report will include the following environmentalinformation for each assessment scenario:

a) a description of and rationale for the selection ofenvironmental attributes, parameters, or propertiesexamined;

6.0

b) for each selected environmental attribute, parameter, orproperty:

i) describe existing conditions. Comment on whetherthe available data are sufficient to assess impactsand mitigative measures. Identify environmentaldisturbance from previous, current, and approved

Addressedthroughout sections7 to 21

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activities that have become part of the baselineconditions,

ii) describe the nature and significance of theenvironmental effects and impacts associated withthe development activities,

iii) present plans to minimize, mitigate or eliminatenegative effects and impacts. Discuss the keyelements of such plans,

iv) present a plan to manage environmental changes andidentify any follow-up programs necessary to verifythe accuracy of the environmental assessment and todetermine effectiveness of measures taken tomitigate adverse environmental affects, and

v) identify residual impacts and comment on theirsignificance;

c) a discussion of the sources of information used in theassessment including a summary of previously conductedenvironmental assessments related to MAXIM’s operations:

i) information sources will include literature andprevious EIA reports and environmental studies,operating experience from current, similar operations;industry study groups; traditional knowledge; andgovernment sources; and

ii) identify any limitations or deficiencies that theinformation may place on the analysis or conclusionsin the EIA report. Discuss how these limitations ordeficiencies will be addressed within the EIA report;

Addressedthroughout sections7 to 21

d) a description of the techniques used to identify and evaluatethe environmental impacts and effects resulting from theproject;

Addressedthroughout sections7 to 21

e) identify where deficiencies in information exist and describeMAXIM’s plan, including rationale, for providing thenecessary information. Where required, undertake studiesand investigations to obtain additional information toaddress the information deficiencies;

Addressedthroughout sections7 to 21

f) provide a sufficient base for the prediction of positive andnegative impacts and the extent to which negative impactsmay be mitigated by planning, Project design, constructiontechniques, operational practices and reclamationtechniques. Impact significance will be quantified wherepossible and assessed including consideration of spatial,temporal and cumulative aspects;

Addressedthroughout sections7 to 21

g) if applicable, present a plan that addresses the adverseimpacts associated with the Project that may require jointresolution by government, industry, and the community.Describe how this plan will be implemented and how it willincorporate the participation of government, industry andthe community; and

Not provided

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h) present baseline biophysical information in a manner thatenables an ecological land classification (ELC) map of theProject Area to be completed to the ecosite classification.

13.0

4.1.5 Modeling

[A] For each model used in the assessment scenarios, provide:

a) a justification for the model used;

b) a documentation of the assumptions used to obtain themodeling predictions; and

c) a discussion of the limitations of the models used and howthese limitations were addressed, including sources of errorand relative accuracy.

Addressedthroughout sections7 to 21 inapplication

4.1.6 The Project and Climate Parameters

[A] Identify stages or elements of the Project that are sensitive tochanges or variability in climate parameters, including frequency andseverity of extreme weather events. Discuss what impact the change toclimate parameters may have on elements of the project that aresensitive to climate parameters.

2.12.5

4.2 Air Quality, Climate and Noise

4.2.1 Baseline Information

[A] Discuss the baseline climatic and air quality conditions includingthe following:

a) the type and frequency of meteorological conditions thatmay result in poor air quality; and

b) appropriate ambient air quality parameters such as SO2,H2S, total hydrocarbons (THC), NOX, VOC, individualhydrocarbons of concern in the THC and VOC mixtures,ground-level ozone (O3), visibility, representative heavymetals, and particulates (TSP, road dust, PM10 and PM2.5).

7.2

[B] Provide representative baseline noise levels. 8.2

4.2.2 Impact Assessment

[A] Identify components of the Project that will affect air quality, and:

a) describe the potential for reduced air quality (includingodours and visibility) resulting from the Project and discussany implications of the expected air quality forenvironmental protection and public health;

b) estimate ground-level concentrations of appropriate airquality parameters;

c) discuss any expected changes to particulate deposition oracidic deposition patterns;

d) identify areas that exceed Potential Acid Input (PAI) criticalloading criteria;

e) discuss interactive effects that may occur as a result of co-exposure of a receptor to all emissions; and

f) describe air quality impacts resulting from the Project, andtheir implications for other environmental resources,including habitat diversity and quantity, vegetation

7.3 and 7.4

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resources, and water quality.

[B] Identify components of the Project that have the potential tocreate increased noise levels and discuss the implications. Present theresults of a noise assessment. Include:

a) potentially-affected people and wildlife;

b) an estimate of the potential for increased noise resultingfrom the development; and

c) the implications of any increased noise levels.

8.3 and 8.4

[C] Describe how air quality and noise impacts resulting from theProject will be mitigated.

7.3 and 7.4, 8.3.2and 8.4.1

[D] Describe the residual air quality and noise effects of the Projectand MAXIM’s plans to manage those effects.

7.3 and 7.4, 8.3.3,8.4.3

4.2.3 Monitoring

[A] Describe the potential for reduced air quality. Describe ambientair quality and noise monitoring that will be conducted during the life ofthe Project to assess air quality and noise and the effectiveness ofmitigation.

[B] Describe monitoring programs MAXIM may implement to monitorthe effects of acid deposition.

7.4.2 and 8.3.7

4.3 Hydrogeology

4.3.1 Baseline Information

[A] Provide an overview of the existing geologic and hydrogeologicsetting. Document any new hydrogeological investigations, includingmethodology and results, undertaken as part of the EIA study, and:

a) present regional and Project Area geology using structurecontour maps, geologic cross sections and isopach maps toillustrate depth, thickness and spatial extent of lithology,stratigraphic units and structural features;

b) present regional and Project Area hydrogeology describing:

i) the major aquifers, aquitards and aquicludes theirspatial distribution, properties, hydraulic connectionsbetween aquifers, hydraulic heads, gradients,groundwater flow directions and velocities. Includemaps and cross sections,

ii) the chemistry of groundwater aquifers includingbaseline concentrations of major ions, metals andhydrocarbon indicators,

iii) the potential discharge zones, potential rechargezones and sources, areas of groundwater-surfacewater interaction,

iv) water well development and groundwater use,including an inventory of groundwater users,

v) the recharge potential for aquifers,

vi) potential hydraulic connection between ash disposalareas and other aquifers due to Project operations,

9.2

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vii) the characterization of areas chosen for ash disposal,including chemical compatibility and containmentpotential, injection capacity, hydrodynamic flowregime, and water quality assessments. Thesuitability of any onsite waste disposal sites should bediscussed and supporting geological informationprovided, and

viii) the locations of major facilities associated with theProject, including facilities for waste storage,treatment and disposal (e.g. deep well disposal) anddescribe site-specific aquifer and shallowgroundwater conditions beneath these proposedfacilities.

4.3.2 Impact Assessment

[A] Describe Project components and activities that have thepotential to affect groundwater resource quantity and quality during thelife of the Project.

[B] Describe the nature and significance of the potential Projectimpacts on groundwater with respect to:

a) inter-relationship between groundwater and surface water interms of surface water quantity and quality;

b) implications for terrestrial or riparian vegetation, wildlife andaquatic resources, including wetlands;

c) changes in groundwater quality;

d) conflicts with other groundwater users, and proposedresolutions to these conflicts;

e) potential implications of seasonal variations; and

f) groundwater withdrawal for Project operations.

[C] Describe programs to manage and protect groundwaterresources including response/mitigation plans that may be considered inthe event that adverse effects are detected.

[D] Describe the residual effects of the Project on groundwaterquality and quantity and MAXIM’s plans to manage those effects.

9.3 and 9.4

4.3.3 Monitoring

[A] Describe monitoring programs proposed to identify impacts togroundwater quality and quantity resulting from the Project and tomeasure the effectiveness of mitigation plans.

9.4.2

4.4 Hydrology

4.4.1 Baseline Information

[A] Describe and map the surface hydrology. Include flow regimes ofstreams in the Project Area.

10.3.1

[B] Provide available surface flow baseline data for both the LocalStudy Area and Regional Study Area, including but not limited to:

a) seasonal variation, low, average and peak flows for keycreeks, river locations, watercourses; and

b) low, average and peak levels for waterbodies/key lakes.

10.2

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[C] Identify any surface water users who have existing approvals,permits or licenses.

10.2

4.4.2 Impact Assessment

[A] Discuss changes to watersheds, including surface and near-surface drainage conditions, potential flow impediment, and potentialchanges in open-water surface areas caused by the Project during allstages of the Project.

[B] Describe the extent of hydrological changes that will result fromdisturbances to groundwater and surface water movement:

a) include changes to the quantity of surface flow, water levelsand channel regime in local watercourses (during minimum,average and peak flows) and water levels in localwaterbodies;

b) assess the potential impact of any alterations in flow on thehydrology in both the Local Study Area and Regional StudyArea and identify all temporary and permanent alterations,channel realignments, disturbances or surface waterwithdrawals;

c) discuss both the Project and cumulative effect of thesechanges on hydrology (timing, volume, peak and minimumflow rates, river regime and lake levels), including thesignificance of effects for downstream watercourses; and

d) identify any potential erosion problems in watercourses dueto the Project.

[C] Discuss changes in sedimentation patterns in receiving waterscaused by the Project.

[D] Describe impacts on other surface water users due to the Project.Identify any potential water use conflicts.

[E] Describe potential downstream impact if surface water isremoved.

[F] Discuss the impact of low flow conditions and in-stream flowneeds (IFN) on water supply and water and wastewater managementstrategies.

[G] Discuss how potential impacts of temporary and permanent roadson the hydrology of peatland/wetland types will be minimized andmitigated.

10.3

[H] Describe mitigation measures to address impacts during theconstruction, operation, decommissioning and reclamation stagesincluding the following:

a) alteration in flow regimes;

b) potential water use conflicts; and

c) increased sediment loadings.

10.3.1.2, 10.3.2.2,and 10.3.3.2

[I] Describe residual effects of the Project on hydrology in both theLocal Study Area and Regional Study Area and MAXIM’s plans tomanage those effects.

10.3.1.3, 10.3.2.3,and 10.3.3.3

4.4.3 Monitoring

[A] Describe monitoring programs to measure the effectiveness of 10.3.1.7, 10.3.2.7,

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mitigation plans.

[B] Discuss any monitoring programs that may be considered toassess the impacts of changes in surface water flows and levels andtheir impacts on aquatic resources, wildlife and vegetation.

and 10.3.3.7

4.5 Surface Water Quality

4.5.1 Baseline Information

[A] Describe the baseline water quality of watercourses andwaterbodies and their seasonal variations and relationships to flow andother controlling factors.

11.2.1

4.5.2 Impact Assessment

[A] Identify Project components that may influence or impact surfacewater quality.

11.1.2

[B] Describe the potential impacts of the Project on surface waterquality:

a) discuss any changes in water quality resulting from theProject that may exceed the Surface Water QualityGuidelines for Use in Alberta or Canadian Water QualityGuidelines;

b) discuss the significance of any impacts on water quality andimplications to aquatic resources (e.g. biota, biodiversityand habitat);

c) discuss seasonal variation and potential effects on surfacewater quality;

d) assess the potential Project related and cumulative impactsof acidifying and other air emissions on surface waterquality; and

e) discuss the effect of changes in surface runoff orgroundwater discharge on water quality in surfacewaterbodies.

11.3 and 11.4

[C] Describe proposed mitigation measures to maintain surface waterquality during the construction, operation, decommissioning andreclamation stages of the Project.

11.3.2.4, 11.3.3.4,11.3.4.4, 11.3.5.4,11.4.1,

[D] Describe the residual effects of the Project on surface waterquality and MAXIM’s plans to manage those effects.

11.3.2.5, 11.3.3.5,11.3.4.5, 11.3.5.5,11.4.3

4.5.3 Monitoring

[A] Describe monitoring programs that may be proposed to assesssurface water quality impacts from the Project and the success ofmitigation measures. Discuss the location of monitoring sites, thefrequency of monitoring, the parameters to be monitored, theimplementation of quality assurance programs, and the numericalmethodology.

[B] Describe how continuous monitoring will be used to evaluateProject effects, and how such monitoring will be used to identify theneed for mitigation.

11.3.2.9, 11.3.3.9,11.3.4.9, 11.3.5.9,11.4.2

4.6 Aquatic Ecology

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4.6.1 Baseline Information

[A] Describe the existing fish and other aquatic resources (e.g.benthic invertebrates). Identify species composition, distribution,relative abundance, movements and general life history parameters.

[B] Describe and map, as appropriate, the fish habitat and aquaticresources of the lakes, rivers and other waters and identify:

a) key indicator species and provide the rationale andselection criteria used;

b) critical or sensitive areas such as spawning, rearing, andover-wintering habitats. Discuss seasonal habitat use,including migration and spawning routes; and

c) the use of the fish resources as existing or potentialaboriginal, sport or commercial fisheries.

12.2.2 and 12.2.3

4.6.2 Impact Assessment

[A] Describe the potential impacts to fish, fish habitat, and otheraquatic resources (e.g. stream alterations and changes to substrateconditions, water quality and quantity) considering:

a) fish tainting, survival of eggs and fry, chronic or acute healtheffects, and increased stress on fish populations fromrelease of contaminants, sedimentation, flow alterations,temperature and habitat changes;

b) potential impacts on riparian areas that could impactaquatic biological resources and productivity;

c) the potential for increased fishing pressures in the regionthat could arise from the increased workforce and improvedaccess as a result of the Project. Identify the implicationson the fish resource and describe any mitigation strategiesthat might be planned to minimize these effects; and

d) changes to benthic invertebrate communities that mayaffect food quality and availability for fish.

12.3 and 12.4

[B] As applicable, discuss the design, construction and operationalfactors to be incorporated into the Project to minimize effects to fish andfish habitat and protect aquatic resources.

2.0 and 12.3.1

[C] Identify plans proposed to offset any loss in the productivity of fishhabitat. Indicate how environmental protection plans address applicableprovincial and federal policies on fish habitat including the developmentof a “No Net Loss” fish habitat objective.

12.3.2 and 12.3.6

[D] Describe the residual effects of the Project on fish, fish habitat,and other aquatic resources and discuss their significance in the contextof local and regional fisheries. Describe MAXIM’s plans to managethose effects.

12.3.2, 12.3.3 and12.3.4

4.6.3 Monitoring

[A] Describe monitoring programs that may be proposed to assessfisheries impacts from the Project and the success of mitigationmeasures.

12.3.7

4.7 Vegetation

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4.7.1 Baseline Information

[A] Describe the existing vegetation and map vegetation communitiesfor each ecosite phase.

13.2.1.2 and 3.2.2

[B] Describe and map peatlands and wetlands, and discuss thedistribution and relative abundance of wetlands.

13.2.2, 13.2.4 and13.2.5

[C] Identify, verify and map the relative abundance of species of rareplants and the ecosite phases where they are found.

13.2.1.2 and 13.2.3

[D] Identify key indicator species and discuss the rationale for theirselection. Identify composition, distribution, relative abundance, habitatrequirements and general life history. Address those species listed as“at Risk, May be at Risk and Sensitive” as listed in The Status of AlbertaSpecies (Alberta Sustainable Resource Development).

13.2.3 and 13.2.6

[E] Discuss the potential of each ecosite phase to support rare plantspecies, plants for traditional and medicinal purposes, old growth forestsand communities of limited distribution. Consider their importance forlocal and regional habitat, sustained forest growth, rare plant habitatand the hydrologic regime.

13.2.3, 13.2.4,13.2.5 and 13.2.6

[F] Describe the regional relevance of landscape units that areidentified as rare.

13.3

4.7.2 Impact Assessment

[A] Identify the amount of vegetation and wetlands to be disturbedduring the life of the Project.

[B] Discuss any potential effects the Project may have on rare plantsor endangered species, as listed in the Status of Alberta Species(Alberta Sustainable Resources Development) and the Alberta NaturalHeritage Information Centre (ANHIC) and Committee on the Status ofEndangered Wildlife in Canada (COSEWIC).

[C] Discuss temporary (include timeframe) and permanent changesto vegetation and wetland communities and:

a) comment on the effects and their implications for otherenvironmental resources (e.g. habitat diversity and quantity,water quality and quantity, erosion potential, recreation andother uses); and

b) comment on the sensitivity to disturbance (including aciddeposition), as well as the techniques used to estimatesensitivity to disturbance and reclamation, of eachvegetation community.

[D] Describe the regional relevance of any ecosite phase to beremoved.

[E] Discuss from an ecological perspective, the expected timelinesfor establishment and recovery of vegetative communities and theexpected differences in the resulting vegetative community structures.

13.3 and 13.4

[F] Provide an ELC map that shows the reclaimed vegetation.Comment on the importance of the size, distribution and variety of thereclaimed landscape units from both a local and regional perspective.

2.11

[G] Compare the pre-disturbance and reclaimed percentages anddistribution of all forested communities in the Project Area and

Not applicable

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determine the amount of commercial and non-commercial forest landbase that will be disturbed by the Project.

[H] Discuss the impact of any loss of peatlands or wetlands, as wellas how this will affect land use, fragmentation and biodiversity. Discussmeasures and techniques that will be used to minimize the impact.

13.3 and 13.4

[I] Provide a mitigation strategy that will minimize Project impactsaddressing the following:

a) mitigation of the adverse effects of site clearing on rareplants and plant communities. Identify any setbacksproposed around environmentally-sensitive areas such assurface waterbodies, riparian areas andpeatlands/wetlands; and

b) measures and techniques that will be used to minimize theimpact of loss of peatlands or wetlands on land use,fragmentation and biodiversity.

13.3.1.2, 13.3.2.2,13.3.3.4 and 13.4.1

[J] Describe the residual effects of the Project on vegetation andMAXIM’s plans to manage those effects.

13.3.1.3, 13.3.2.3,13.3.3.5 and 13.4.3

4.7.3 Monitoring

[A] Describe monitoring programs that may be proposed to assessvegetation impacts from the Project and the success of mitigationmeasures.

13.4.2

4.8 Wildlife

4.8.1 Baseline Information

[A] Describe and map existing wildlife resources (amphibians,reptiles, birds and terrestrial and aquatic mammals), their use andpotential use of habitats.

[B] Identify key indicator species and discuss the rationale for theirselection. Identify composition, distribution, relative abundance,seasonal movements, movement corridors, habitat requirements, keyhabitat areas, and general life history. Address those species listed as“at Risk, May be at Risk and Sensitive” as listed by Alberta SustainableResource Development and COSEWIC.

14.2

4.8.2 Impact Assessment

[A] Describe Project components and activities that may affectwildlife and wildlife habitat.

14.1.3

[B] Describe the potential changes to wildlife:

a) evaluate potential impacts on wildlife populations, habitatuse, habitat availability/quality and food supply during allphases of the Project. Consider habitat loss, abandonment,reduced effectiveness, fragmentation or alteration as itrelates to reproductive potential and recruitment for regionalwildlife populations over the life of the Project;

b) describe the spatial and temporal changes to habitat (type,quality, quantity, diversity and distribution) and to wildlifedistribution, relative abundance, movements, habitatavailability and the potential to return the area to pre-disturbed wildlife habitat/population conditions, including:

14.3

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i) potential effects on wildlife as a result of changes toair and water quality, including both acute and chroniceffects on animal health,

ii) potential effects on wildlife due to improved or alteredaccess into the area (e.g. vehicle collisions withwildlife), obstructions to daily or seasonal movements,noise and hunting mortality during operations andafter reclamation, and

iii) map the anticipated changes due to the Project andother planned activities in both the Local Study Areaand Regional Study Area to describe potential effectsof habitat fragmentation and the implications towildlife.

[C] Provide a strategy and mitigation plan to minimize impacts onwildlife habitat during the life of the Project and to return productivewildlife habitat to the area, considering:

a) consistency of the plan with applicable regional, provincialand federal wildlife habitat objectives and policies;

b) habitat enhancement measures and a schedule for thereturn of habitat capability to areas impacted by the Project;

c) the use of setbacks to provide for the protection of riparianhabitats, interconnectivity of such habitat and theunimpeded movement by wildlife species using the habitat;

d) the need for access controls or other managementstrategies to protect wildlife during and after Projectoperations; and

e) measures to prevent habituation of wildlife (e.g. blackbears), increasing the potential for human-wildlifeencounters and consequent destruction of wildlife, includingany staff training program, garbage containment or regularfollow-up.

14.3.2

[D] Describe the residual effects of the Project on wildlife and wildlifehabitat in both the Local Study Area and Regional Study Area andMAXIM’s plans to manage those effects.

14.3.3, 14.3.5 and14.3.2

4.8.3 Monitoring

[A] Describe monitoring programs that may be proposed to assesswildlife impacts from the Project and the effectiveness of mitigationstrategies and habitat enhancement measures, giving special attentionto sensitive species.

14.3.6

4.9 Biodiversity and Fragmentation

4.9.1 Baseline Information

[A] Describe the terrestrial and aquatic biodiversity metrics that willbe used to characterize the existing ecosystems and probable effects ofProject development, and that will represent broad taxonomicassemblages, and:

a) describe the process and rationale used to select biotic andabiotic indicators for biodiversity within selected taxonomicgroups;

13.2 and 14.2

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b) determine the relative abundance of species in eachecological unit (e.g. ecosite phase);

c) provide species locations, lists and summaries of observedand estimated species richness and evenness for eachecosite phase;

d) provide a measure of biodiversity on baseline sites that arerepresentative of the proposed reclamation ecosites; and

e) rank each ecological unit for biodiversity potential bycombining measures of species richness, overlap in specieslists, significance of individual species or associations,uniqueness and other appropriate measures. Describe thetechniques used in the ranking process.

[B] Describe the current level of habitat fragmentation.

4.9.2 Impact Assessment

[A] Discuss the contribution of the Project to any anticipated changesin regional biodiversity and the potential impact to local and regionalecosystems.

[B] Identify and evaluate the extent of potential effects fromfragmentation that may result from the Project.

[C] Discuss the measures to minimize any anticipated changes inregional biodiversity.

[D] Describe the residual effects of the Project on biodiversity andfragmentation and MAXIM’s plans to manage those effects.

13.3 and 13.4, 14.3and 14.4

4.9.3 Monitoring

[A] Describe monitoring programs proposed to measure changes tobiodiversity and fragmentation caused by the Project and theeffectiveness of mitigation measures.

13.4.2 and 14.4.2

4.10 Terrain and Soils

4.10.1 Baseline Information

[A] Provide descriptions and maps of the terrain and soils conditions,including:

a) surficial geology and topography;

b) the soil types and their distribution. Provide an ecologicalcontext to the soil resource by supplying soil surveyinformation that includes Survey Intensity Level (SIL) 2 forany undisturbed areas within the Project Area;

c) the suitability and availability of soils within the Project Areafor reclamation;

d) soils that could be affected by the Project with emphasis onpotential acidification (by soil type); and

e) descriptions and locations of erosion sensitive soils.

15.2

4.10.2 Impact Assessment

[A] Describe Project activities and other related issues that couldaffect soil quality (e.g. compaction, contaminants) and:

a) indicate the amount (ha) of surface disturbance from plant,field (pipelines, transmission lines and access roads),

15.1.3 and 15.3

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aggregate and borrow sites, construction camps, and otherinfrastructure-related construction activities;

b) provide an inventory of the pre- and post-disturbance landcapability classes for soils in the Local Study Area anddescribe the impacts to land capability due to the Project.Map the size and distribution of pre-disturbance landcapability classes and indicate the size and location of soiltypes and land capability classes that will be disturbed;

c) discuss the relevance of any changes for the local andregional landscapes, biodiversity, productivity, ecologicalintegrity, aesthetics and future use resulting fromdisturbance during the life of the Project;

d) identify the potential acidification impact on soils anddiscuss the significance of predicted impacts by acidifyingemissions resulting from the Project;

e) describe the impact of the Project development on soiltypes and reclamation suitability and the approximatevolume of soil materials for reclamation. Discuss anyconstraints or limitations to achieving vegetation/habitatreclamation based on anticipated soil conditions (e.g.compaction, contaminants, soil moisture, nutrient depletion,erosion, etc.);

f) discuss the potential for soil erosion during the life of theProject;

g) identify the environmental effects of the proposed electricpower generation project on the landscape during the life ofthe Project; and

h) discuss the potential for upset conditions and theirenvironmental effects.

[B] Provide a mitigation plan to address the following:

a) possible measures to minimize surface disturbanceincluding the use of existing clearings for Projectdevelopment;

b) possible actions to address potential effects of aciddeposition;

c) actions to mitigate effects of any constraint or limitation tohabitat restoration such as compaction, contaminants, soilmoisture, erosion, nutrient regime, etc.;

d) possible measures to mitigate changes to ground surface(temperature, heave and subsidence) during operations;

e) possible actions to address impacts to land capability; and

f) any other measures to reduce or eliminate the potentialimpacts that the Project may have on soil capability and/orquality.

15.3.3 and 15.4.1

[C] Describe the residual effects of the Project on terrain and soilsand MAXIM’s plans to manage those effects.

15.3.4, 15.3.5.3,15.4.1 and 15.4.3

4.10.3 Monitoring

[A] Describe monitoring programs proposed to measure Project 15.4.2

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impacts on terrain and soils and the success of mitigation measures.

4.11 Land Use

4.11.1 Baseline Information

[A] Identify the current land uses, including oil and gas development,agriculture, forestry, tourism, cultural use, food collection, trapping,fishing, hunting and other outdoor recreational activities.

16.2.4, 16.2.5,16.3.1.1, 16.3.2.1and 16.3.3.1

[B] Identify and map all Crown land including bed and shore. 16.2.3.2

[C] Identify unique sites or special features such as Natural Areas,Environmentally Significant Areas, and Heritage Rivers.

16.2.6 and 16.2.7

[D] Identify any land use policies and resource managementinitiatives that pertain to the Project, and discuss how the Project will beconsistent with the intent of these initiatives.

16.2.3

4.11.2 Impact Assessment

[A] Identify the potential impact of the Project on land uses, including:

a) impacts to unique sites or special features;

b) anticipated impacts related to changes in public access;

c) secondary effects, such as increased hunter, angler andother recreational access and facilitated predatormovement, that may result from linear development;

d) the implications of relevant land use policies and resourcemanagement initiatives for the Project, including anyconstraints to development;

e) potential impacts to aggregate reserves that may be locatedon land under MAXIM’s control and reserves in the region;

f) the impact of development and reclamation on commercialforest harvesting in the Project Area. Include opportunitiesfor timber salvage, revegetation, reforestation and harvestfor the reduction of fuel hazard;

g) the amount of commercial and non-commercial forest landbase that will be disturbed by the Project. Compare thepre-disturbance and reclaimed percentages and distributionof all forested communities in the Project Area;

h) how the Project disturbance impacts Annual Allowable Cutsand quotas within the FMA;

i) the potential impact on existing land uses of anticipatedchanges (type and extent) to the pre-disturbancetopography, elevation and drainage pattern within theProject Area; and

j) implications of the Project on regional recreational activities,public access and other land uses during and afterdevelopment activities.

16.1.2.1 and 16.3

[B] Discuss possible mitigation strategies to address:

a) the need for, and plans to address, access managementduring and after Project operations;

b) the process for addressing the needs of other land users inthe Local Study Area;

16.3.1.3, 16.3.2.3,16.3.3.3, and16.4.2

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c) measures to mitigate impacts on land use created by theProject; and

d) how potentially-affected aggregate reserves will besalvaged and stockpiled with input provided by AlbertaTransportation and Alberta Sustainable ResourceDevelopment.

[C] Describe the residual effects of the Project on land use andMAXIM’s plans to manage those effects.

16.3.1.4, 16.3.2.4,16.3.3.4, 16.4.1,and 16.4.4

4.11.3 Monitoring

[A] Describe monitoring programs proposed to measure land useimpacts resulting from the Project and the effectiveness of mitigationmeasures.

16.4.2

5.0 Historic Resources

[A] Describe consultation with Alberta Culture and Community Spirit(ACCS) concerning the need for a Historical Resource ImpactAssessment (HRIA) for the Project, and:

a) provide a general overview of the results of any previoushistorical resource studies that have been conducted in theStudy Area, including archaeological resources,palaeontological resources, historical period sites, and anyother historical resources as defined within the HistoricalResources Act;

b) summarize the results from the field program performed toassess archaeological, palaeontological and historicalsignificance of the Local Study Area;

c) provide a summary of the results of the HRIA conducted toassess the potential impact of the Project onarchaeological, palaeontological and historical resources;

d) provide an outline of the program and schedule of fieldinvestigations that ACCS may require MAXIM to undertaketo further assess and mitigate the effects of the Project onhistorical resources; and

e) document any stakeholder concerns with respect to thedevelopment of the Project based on the historicalsignificance of the Study Area.

17.0

6.0 Traditional Ecological Knowledge and Land Use

[A] Describe consultation with aboriginal communities and provide:

a) the extent of traditional use of land in the Local Study Area.Discuss the vegetation and wildlife used for traditional, food,ceremonial, medicinal and other purposes, and anypotential effects the Project may have;

b) traditional uses including fishing, hunting, nutritional ormedicinal plant harvesting, and cultural use by localaboriginal peoples; and

c) a map of cabin sites, spiritual sites, graves and othertraditional use sites considered as historic resources underthe Historical Resources Act (if the aboriginal community is

3.0 and 18.0

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willing to have these locations disclosed.)

[B] Determine the impact of development on these uses and identifypossible mitigation strategies.

18.3 and 18.4

7.0 Public Health and Safety Assessment

[A] Describe those aspects of the Project that may have implicationsfor public health or the delivery of regional health services. Determinewhether there may be implications for public health arising from theProject. Specifically:

a) assess the potential health implications of the compoundsthat will be released to the environment from the proposedProject in relation to exposure limits established to preventacute and chronic adverse effects on human health;

b) provide the data, exposure modeling calculations, anddescribe the methods the Proponent used to assessimpacts of the Project on human health and safety;

c) provide information, including chemical analyses, andmodeling results on samples of selected environmentalmedia (e.g., soil, water, air, vegetation, wild game, etc.)used in the assessment;

d) discuss the potential for changes to water quality, air qualityand soil quality to increase human exposure tocontaminants taking into consideration all Project activities;

e) identify the potential human health impact of the potentialcontamination of country foods and natural food sourcestaking into consideration all Project activities;

f) document the health concerns raised by stakeholdersduring consultation on the Project;

g) document any health concerns identified by aboriginalcommunities due to impacts of existing development and ofthe Project specifically on their traditional lifestyle andinclude an aboriginal receptor type in the assessment;

h) assess the cumulative human health effects to receptors,including First Nations and Métis receptors;

i) assess the cumulative health effects that are likely to resultfrom the Project in combination with other existing,approved and planned Projects or reasonably-foreseeableactivities in the region;

j) as appropriate, describe anticipated follow-up work,including regional cooperative studies. Discuss how suchwork will be implemented and coordinated with ongoing air,soil and water quality initiatives;

k) describe the potential health and safety impacts due tohigher regional traffic volumes and the increased risk ofaccidental leaks and spills; and

l) discuss possible mitigation strategies to minimize thepotential impact of the Project on human health.

20

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[B] Describe those aspects of the Project that may have implicationsfor public safety. Determine whether there may be implications for publicsafety arising from the Project. Specifically:

a) provide a summary of the Project’s emergency responseplan;

b) document the safety concerns raised by stakeholdersduring consultation on the Project;

c) describe how local residents will be contacted during anemergency and the type of information that will becommunicated to them;

d) describe the existing agreements with area municipalities orindustry groups such as safety cooperatives, emergencyresponse associations and municipal emergency responseagencies;

e) describe the potential safety impacts due to higher regionaltraffic volumes; and

f) discuss mitigation plans to ensure workforce and publicsafety during the life of the Project. Include prevention andsafety measures for wildfire occurrences, water saturatedplume from the cooling towers, icy roads in the wintermonths, accidental release or spill of chemicals to theenvironment and failures of structures retaining water orfluid wastes.

2.12.6

8.0 Socio-Economic Assessment

8.1 Baseline Information

[A] Describe the existing socio-economic conditions in the region,including for the communities in the region.

[B] Describe factors that may affect existing socio-economicconditions including:

a) population changes;

b) MAXIM’s policies and programs regarding the use ofregional and Alberta goods and services;

c) a project schedule and a general description of the overallengineering and contracting plan for the Project;

d) workforce requirements for the Project including adescription of when peak activity periods will occur. Identifylocal employment and business development opportunitiesthe Project may create; and

e) planned accommodations for the workforce.

19.2

8.2 Impact Assessment

[A] Describe the socio-economic effects of the Project, including:

a) impacts on the communities in the region and on Albertaincluding:

i) local employment and training,

ii) local procurement,

iii) population changes,

iv) housing concerns in local communities,

19.3 and 19.4

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v) construction camps,

vi) recreational activities,

vii) trapping, hunting and fishing,

viii) effects on First Nations and Métis (e.g. traditional landuse and culture), and

ix) regional and provincial economic benefits;

b) estimated industrial benefits including Alberta, otherCanadian, and non-Canadian percentages of total Projectcost for engineering and project management, equipmentand materials, construction labour and total overall Project;

c) impacts of the Project on the availability of affordablehousing and the quality of health care services. Provide asummary of any discussions that have taken place with thelocal municipalities and the Regional Health Authorityconcerning housing availability and health care servicesrespectively;

d) discuss any effects expected on primary and secondaryhighway systems and other regional roads caused byanticipated traffic changes;

e) if a construction camp is needed, identify:

1. its location,

2. the number of workers it is intended to house,

3. whether the camp will service the Project only orother clients,

4. the length of time the camp will be in service, and

5. describe what services will be provided in the camp(e.g., security, recreation and leisure, medicalservices); and

f) the impact on local and regional infrastructure andcommunity services, including consideration of municipal“hard services”, education/training services, social services,urban and regional recreation services, law enforcementand emergency services.

[B] Discuss options for mitigating impacts including:

a) the Proponent’s policies and programs regarding the use ofregional and Alberta goods and services;

b) plans to work with First Nations and Métis communities andgroups and other local residents and businesses withregards to employment, training needs, and other economicdevelopment opportunities arising from the Project;

c) impacts to local and regional transportation infrastructure;

d) steps that have been undertaken by industry, themunicipality, provincial government or through regional andcooperative initiatives to address socio-economic concernsand impacts to local and regional transportationinfrastructure;

e) the potential to avoid overlap with other Projects that arereasonably anticipated during the life of the Project;

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f) mitigation plans that will be undertaken to address issuesrelated to the availability of affordable housing and thequality of health care services; and

g) strategies to mitigate socio-economic concerns raised bythe local municipality and other stakeholders in the region.

[C] Describe the residual effects of the Project on socio-economicconditions and the measures MAXIM plans to manage those effects.

8.3 Monitoring

[A] Discuss monitoring plans proposed to measure the success ofmitigation activities.

19.4.2