Pakwash Lake Owners Association, Formal Stakeholder Impact Submission

FORMAL STAKEHOLDER IMPACT SUBMISSION

DATE: May 11, 2026
TO: Impact Assessment Agency of Canada (GreatBear@iaac-aeic.gc.ca (mailto:GreatBear@iaac-aeic.gc.ca))
RE: Project 85832 – Great Bear Project – Formal Stakeholder Impact Statement
FROM: Kim Budweg, Owner, Pakwash Lake Camp; Representative, Pakwash Lake Owners Association
SUBJECT: Stakeholder Submission – Environmental Protection, Monitoring, and Enforceable Thresholds

INTRODUCTION

As a primary downstream stakeholder, I am submitting this response regarding the proposed Great Bear Project and its potential effects on the Pakwash Lake–Chukuni River watershed and the regional tourism economy.

Having reviewed the Impact Statement, I acknowledge that it generally addresses several core requirements under the Impact Assessment Act, including:

· Identification of valued ecosystem components

· Description of potential pathways of environmental effects

· Consideration of mitigation measures

· Assessment of cumulative effects

These elements appear to have been developed through consultation and technical study. However, the effectiveness of the proposed mitigation measures is fundamentally dependent on robust monitoring, transparent reporting, and enforceable thresholds tied to clear management actions.

Without these elements, even well-designed mitigation frameworks risk becoming ineffective over time.

1. AQUATIC ECOSYSTEM INTEGRITY AND FISHERIES

The Pakwash Lake and Chukuni River system supports a high-value recreational fishery that depends on stable water quality and intact spawning habitats.

Key sensitivities include:

· Dependence of Walleye and Northern Pike on forage species (e.g., baitfish), which are highly sensitive to water chemistry changes

· Requirement for clean, oxygenated, low-sediment spawning substrates

· Vulnerability of early life stages to turbidity, contaminants, and oxygen depletion

While mitigation measures are described in the Impact Statement, their success depends on maintaining water quality within limits that prevent measurable ecological change.

2. SULPHATE–MERCURY INTERACTION (CRITICAL RISK)

A key risk requiring careful management is the relationship between sulphate loading and mercury methylation.

Increased sulphate concentrations can stimulate microbial processes that convert inorganic mercury into methylmercury, which:

· Bioaccumulates in fish tissue

· Directly affects fish consumption safety

· Poses long-term ecological and human health risks

The Impact Statement identifies this pathway; however, its management requires:

· Site-specific modelling of sulphate loading impacts

· Ongoing downstream monitoring in water, sediment, and fish tissue

· Long-term verification that methylmercury production is not increasing

Given the persistence and bioaccumulative nature of mercury, this risk requires a precautionary and measurable management approach.

3. CYANIDE MANAGEMENT (ACUTE TOXICITY RISK)

Cyanide is commonly used in gold extraction processes and represents a high acute toxicity risk to aquatic ecosystems if released to receiving waters.

Unlike sulphate and mercury, which present longer-term and bioaccumulative risks, cyanide can cause immediate lethal and sublethal effects on fish and aquatic organisms at relatively low concentrations, including:

· Impaired respiration in fish

· Disruption of feeding and predator avoidance behavior

· Direct mortality in sensitive species and early life stages

While the Metal and Diamond Mining Effluent Regulations establish allowable limits for total cyanide in effluent, these limits may not fully protect sensitive downstream ecosystems, particularly high-value fisheries such as those in the Pakwash Lake system.

Required Monitoring and Controls

To ensure adequate protection:

· Continuous or high-frequency monitoring of cyanide concentrations at discharge points and in receiving waters

· Differentiation between total cyanide and free cyanide, with emphasis on the more toxic free cyanide fraction

· Monitoring during all operational phases, including upset conditions and seasonal variability

Recommended Protective Threshold

· Cyanide levels in receiving waters should remain at or near baseline conditions

· A precautionary target of ≤ 0.005 mg/L (5 µg/L) free cyanide in receiving waters is recommended to protect aquatic life

Management Triggers

Where monitoring indicates elevated cyanide levels:

· Immediate investigation must occur

· Operational adjustments must be implemented

· Discharge must be reduced or halted if necessary

Given the rapid toxicity of cyanide, management responses must be immediate and predefined, not delayed through long-term adaptive processes.

4. TAILINGS MANAGEMENT AND LONG-TERM RISK

Tailings storage represents one of the highest consequence risks associated with mining projects.

While the Impact Statement outlines mitigation and design approaches, it is essential that:

· Design standards reflect best available technology and minimize long-term risk

· Full breach scenario modelling is completed and publicly available

· Downstream impact pathways, including timing and extent of potential release, are clearly understood

Equally important is ensuring that financial assurance fully reflects worst-case scenarios, including long-term water treatment if required.

5. SEDIMENT CONTROL AND AIRBORNE DUST

Construction and operational activities have the potential to affect water quality through sediment mobilization and airborne deposition.

Key considerations include:

· Increased turbidity affecting fish habitat and spawning success

· Deposition of dust containing metals or other contaminants into aquatic systems

Mitigation measures are described; however, their effectiveness depends on:

· Continuous monitoring

· Clearly defined thresholds

· Immediate response when limits are exceeded

6. RESORT OPERATIONS AND SOCIO-ECONOMIC IMPACTS

Pakwash Lake Camp and surrounding tourism operations rely on:

· High water quality

· A quiet, low-impact environment

· A perception of wilderness and ecological integrity

Potential project-related risks include:

· Degradation of water quality

· Increased noise and light disturbance

· Increased traffic and associated safety concerns

Protection of these values requires that environmental changes remain below levels that are detectable to users and do not alter the character of the area.

7. MONITORING, TRANSPARENCY, AND ADAPTIVE MANAGEMENT

The Impact Statement places significant reliance on adaptive management. While this is appropriate in principle, its effectiveness depends on:

a) Continuous and Credible Monitoring

· Real-time or high-frequency monitoring of key water quality indicators

· Long-term consistency in monitoring programs

· Independent verification where appropriate

b) Public Transparency

To maintain accountability and stakeholder confidence, monitoring results should be:

· Made available through a publicly accessible online dashboard or website

· Reported in a clear and understandable format

· Updated regularly (real-time where possible; otherwise monthly/quarterly)

c) Ongoing Stakeholder Communication

· Annual reporting provided directly to stakeholders

· Clear summaries of baseline conditions and any changes observed over time

· Identification of trends, not just raw data

This level of transparency is necessary to ensure that monitoring programs remain robust throughout the life of the project and are not reduced over time.

8. REQUIRED MONITORING THRESHOLDS AND MANAGEMENT TRIGGERS

To ensure that mitigation measures are effective, monitoring must be tied to clear, enforceable thresholds that trigger management action.

Where federal regulations do not define sufficiently protective limits, site-specific thresholds should be established to prevent measurable degradation of receiving waters, informed by recognized guidance such as that developed by the Canadian Council of Ministers of the Environment.

Water Quality Protection

· No measurable increase above baseline conditions for key contaminants

· Specific attention to sulphate, mercury, nutrients, and cyanide

Sulphate

· ≤ 10 mg/L increase above baseline

Mercury

· No measurable increase in fish tissue concentrations over baseline

Cyanide

· Maintain concentrations at or near baseline in receiving waters

· Target: ≤ 0.005 mg/L free cyanide

Turbidity / Suspended Solids

· Maintain within a narrow range above baseline

· Immediate response if thresholds are exceeded

Dissolved Oxygen

· Maintain levels sufficient to fully protect spawning habitat

Management Triggers

Monitoring results must be directly linked to:

· Immediate investigation

· Operational adjustment

· Temporary suspension of activities if required

Threshold exceedances must result in timely and predefined actions, not delayed responses.

9. FINANCIAL ASSURANCE

Financial assurance must reflect the full life-cycle risk of the project and include:

· 100% coverage of reclamation costs

· Funding for potential tailings failure scenarios

· Long-term water treatment, potentially extending decades beyond closure

This is necessary to ensure that environmental and financial risks are not transferred to the public.

CONCLUSION

The Impact Statement demonstrates that key environmental components, pathways, and mitigation measures have been identified. However, the success of these measures depends on:

· Clearly defined and protective monitoring thresholds

· Strong transparency and reporting mechanisms

· Enforceable links between monitoring results and management action

· Adequate long-term financial assurance

Approval of the Great Bear Project should therefore be contingent upon the implementation of a rigorous, transparent, and enforceable monitoring and management framework that ensures:

· No measurable degradation of water quality

· Protection of fisheries and aquatic ecosystems

· Prevention of mercury bioaccumulation

· Control of cyanide to prevent acute toxicity risks

· Preservation of the environmental conditions that support the regional tourism economy

Ongoing public reporting and annual stakeholder communication will be essential to maintaining accountability and confidence over the life of the project.

Sincerely,

Kim Budweg & Denis Grenier, Owners, Pakwash Lake Camp
Bill & Laura Deschamps, Owners, Trout River Lodge

Mark & Bonnie Sobchuk

Rob & Nancy Rowe , Owners, Snake Falls Camp

Keith & Debbie Fretz, Owners Pakuni Lodge

Gabe & Shirley Jette’. Owners Jette’s Adventures

Carl Bleich

Buckner Family, Connelly Family, Chevalier Family

Carolanne Watson

Bill & Mary Candline

Ron Brownlee

Jennifer & Darrell Brochkowski

John McDonald

Kevin & Diane Johnson

Richard & Shawna Thibeault

Ken Anderson & Anderson Family