Annexes to the Social Impact Assessment for the ISUA Iron Ore Project for London Mining Greenland A/S



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Transkript:

to the Social Impact Assessment for the ISUA Iron Ore Project for London Mining Greenland A/S (in compliance with the BMP Guidelines on SIA of November 2009) March 2013 v

TABLE OF CONTENTS PAGE ANNEX 1: TERMS OF REFERENCE 1 ANNEX 2: ANNEXES TO TERMS OF REFERENCE 21 ANNEX 3: BASELINE APPENDICES 44 ANNEX 4: PROJECT CONTRACT PACKAGES 52 ANNEX 5: HS-ANALYSIS OF LOCAL USE STUDY ISUA 54 ANNEX 6: CLOSURE CONCEPT FOR THE ISUA MINE 67 ANNEX 7: ACCOMODATION PLANS 70 v

Page 1 of 84 ANNEX 1: TERMS OF REFERENCE Terms of Reference for the Social Impact Assessment for the ISUA Iron Ore Project for London Mining Greenland A/S (in compliance with the BMP Guidelines on SIA of November 2009) October 2010 1

Page 2 of 84 TABLE OF CONTENTS PAGE 1 INTRODUCTION 3 1.1.1 Purpose of the SIA 3 1.2 Regulatory framework 4 1.2.1 The political situation in Greenland 4 1.2.2 Legislation in Greenland 4 1.2.3 International Labour Organization Conventions 5 1.3 Brief description of the ISUA Iron Mining Project and the context 5 1.3.1 Expected work force and working conditions 7 1.4 The SIA proces 8 1.4.1 Study team 8 1.4.2 Approach to SIA 9 1.4.3 Study area and temporal boundaries 10 1.5 Key social issues to be addressed in relation to the impacts of the project 10 1.6 Public participation and Stakeholder involvement 11 1.6.1 List of stakeholders 11 1.6.2 Proposed Stakeholder involvement during the SIA Process 12 1.7 SIA methodologies 15 1.7.1 Baseline study 15 1.7.2 Data collection and research from secondary data 15 1.7.3 Data collection and research from primary sources 15 1.7.4 Impact Analysis Methodologies 16 1.8 Reporting format of SIA report 17 1.9 SIA time schedule 18 1.10 Recommendations 18 1.10.1 Recommendations for project design 18 1.10.2 Preliminary recommendation for Impact and Benefit Plan and other implementation arrangements 19 1.11 Documents sent to consultation 19 1.12 References 20 2

Page 3 of 84 INTRODUCTION This Terms of Reference for the Social Impact Assessment, SIA, of the Isua Project is the result of the scoping phase for the preparation of the Social Impact Assessment (SIA), which London Mining Greenland a/s will carry out in relation to the preparation of the needed permits and licences for exploitation of the Isua Iron Project in West Greenland, 150 km Northeast of Nuuk. The project includes the development of an open pit mine, ore processing plant, product transfer system to the port by a slurry pipeline, shipping facilities, and all necessary facilities and infrastructures. The port site will be located at Taseraarssuk Bay approximately 70 km north-east of Nuuk. The current design production rate is 10 million tons per annum (MTPA) of iron ore concentrate, containing approximately 70.2% Fe and 2% of SiO2+Al2O3. The project expects to employ between 500 and 600 workers during operations and almost double as much during the construction phase. The scoping document was presented and discussed both with the authorities including the Bureau of Minerals and Petroleum, BMP, and stakeholders in a workshop held in Nuuk the 18 th November 2009. The objective was to verify the list key stakeholders, scope of the study, basic assumptions and main issues and questions to be addressed by the SIA study for the project as known in November 2009. The comments and inputs from the stakeholders, received during the workshop and further sent by key informants, where incorporated in this Terms of Reference (ToR). The ToR is based on the current available information and the Pre Feasibility Study (PFS), of the Isua Project for 10 MTPA, finalised in June 2010 and the expected schedule of activities as known in October 2010. After the finalization of the PFS, most features of the project have been defined, schedule of activities has been adjusted and more precise economic and labour figures are available. Particularly number of workers and other aspects related to labour conditions has been considered in the updating of the ToR during 2010. Grontmij Carl Bro A/S has been appointed as consultant for London Mining Greenland a/s to carry out the SIA. A number of other studies and assessments, like the Feasibility Study, and the Environmental Impact Assessment, etc. are being carried out during 2010 and 2011 in order to finalise the design and prepare for the needed permits and licences. The SIA will be prepared according to the SIA Guidelines from Bureau of Minerals and Petroleum (BMP) of November 2009. This document will be referred to as the Guidelines in this report. 1.1.1 Purpose of the SIA The overall objective of the SIA is to identify and analyse the potential impacts of a proposed mining activity and to recommend initiatives, realize sustainable development opportunities as well as to mitigate the negative impacts. According to the Guideline the purpose of the SIA are to: 3

Page 4 of 84 Engage all relevant stakeholders in consultations and public hearings; Provide a detailed description and analysis of the social pre-project baseline situation as a basis for development, mitigation and future monitoring; Provide an assessment based on collected baseline data to identify both positive and negative social impacts at both local and national level; Optimize positive impacts and mitigate negative impacts from the mining activities throughout the project lifetime; Develop a Benefit and Impact Plan (BIP) for implementation of the Impact Benefit Agreement (IBA). London Mining Greenland a/s also expects to identify further areas of research and development within the socio-economic aspects where a proactive action is necessary or advisable for improving the socio-economic and sustainability performance of the project. 1.2 Regulatory framework 1.2.1 The political situation in Greenland Greenland has been under home-rule from Denmark since 1979. On June 21, 2009, the new constitution was introduced after the referendum for the Government of Greenland in November 2008 and country status changed as self rule. Greenlandic is now the only official language in Greenland. Under the Government of Greenland, Greenland will become a subject under international law in matters that are within its jurisdiction. Greenland can then enter into agreements and establish bilateral and multilateral relationships with other states. Greenland is member of the Nordic Council and Nordic Council of Ministries. This membership with other Nordic Countries and autonomous regions facilitates parliamentary cooperation among the members, particularly in relation to nature and environmental issues. The current Environmental Action Plan, 2009-2012 focuses on climate change, the use and discharge of hazardous chemicals protection of marine ecosystems and protection and utilization of biological diversity. Greenland is also member of the Environmental Artic Council since 1996 and the Inuit Circumpolar Council ICC. 1.2.2 Legislation in Greenland The main legislation for this project will be the Act no. 7 of 7 December 2009 on Minerals and Resources The Mineral Resources Law which came into force on January 1, 2010. Other relevant Greenlandic legislation which will be considered during the SIA will be on: Conditions for employment (Act no. 1048 of 26 October 2005 on Labour and working environment in Greenland). Immigration (Regulation no. 150 of 23 February 2001 (Danish regulation)). The Greenlandic Working Environment Act no. 1048 of Occtober 26 2005. 4

Page 5 of 84 Safety on Sea Act No. 882 of August 2008 wich rules the implementation under Greenlandic law of the International Convention on safety at Sea (SOLAS, 1974), the international convention for the prevention of pollution from ships, 1973 and the modified protocol (MARPOL), 1978. United Nations Framework Convention on Climate Change 1.2.3 International Labour Organization Conventions The following International Labour Organizations Conventions of relevance for this project will be: International Labour Organization (ILO) Convention No 155 and 176 concerning occupational safety and health in mines. ILO Convention No. 87 and 98 concerning the right to organize and collective bargaining convention. ILO Convention No. 45, 100 and 105 concerning discrimination and equal remuneration. ILO Convention No. 169 Which calls for prior consultation with indigenous peoples or ethnic groups when seeking to undertake any activities or project in the territories. 1.3 Brief description of the ISUA Iron Mining Project and the context London Mining PLC Inc. is planning to develop its Isua Project, located approximately 150 km northeast of Nuuk. The ore body is located on the edge of the ice cap. The project includes the development of an open pit mine, ore processing plant, product transfer system to the port by a slurry pipeline, shipping facilities, and all necessary facilities and infrastructures. The current design production rate is 10 million tons per annum (MTPA) of iron ore concentrate, containing approximately 70.2% Fe and 2% of SiO2+Al2O3. According to the mining plan, an average of 21.8 million tons of ore and 20.7 million tons of waste and ice per year at a cut-off grade of 25% Fe will be extracted over a 21 year mine life. The total ore tonnage is estimated to be 457.6 Mt and total waste (waste rock and ice) is estimated to be 418.1 Mt, including only 195.2 Mt of waste rock. The process plant is nominally designed to produce 10 million tons of iron ore concentrate per year. The final product is premium quality blast furnace (BF) grade pellet feed with less than 2.0% SiO2 + Al2O3. The final product will be delivered to the port by a 103 km long insulated and heat-traced pipeline. The site water management system including a water management pond (lake 792) and a tailings pond (lake 750). 5

Page 6 of 84 To ensure that the water quality will meet the regulatory requirements, the underwater tailings disposal concept is adopted. Over 21 years of operations, a total tailings volume of approximately 250 Mt will be deposited in the tailings pond with a 3 m deep water cover during operation and at closure. The mine waste rock management is based on the progressive closure concept to minimize the environmental impact during the operation and at closure. The estimated workforce at the mine camp is approximately.500. The accommodation facilities for the plant area are designed to accommodate approximately 220 people includes the dormitories, kitchen/dinning facilities, recreational facilities (gym, library, etc.) and general service space. The accommodation facilities and offices are connected to the working places trough a enclose corridor, or utilidor- for easy the movement of workers and vehicles under hard weather conditions. The utilidor doubles as pipe rack and cable trays to link the plant and complex. The port site will be located at Taseraarssuk Bay approximately 70 km north-east of Nuuk, consisting of a main floating wharf and a secondary wharf for tug berthing. The onshore port facilities include the slurry receiving station and dewatering plant concentrate storage system and ship-loading facility. There will be accommodation facilities and services for the workforce at port site, approximately 70 persons. It is expected that approximately 43 persons will work at the port site. The infrastructure for the project includes, but is not limited to, the following: Electrical installed power of 110 MW (100 MW at the process plant and 10 MW at the port); Heat recovery, from power generation, at both the plant and port sites; Water supply, treatment and distribution (potable/process/fire); Sanitary sewage collection, treatment and disposal; Fuel storage (adequate for 5 weeks of operation) and distribution for mine, plant and port operations; Lubricants and other fluid storage and distribution; Solid waste collection, treatment and disposal; Accommodation facilities including catering and medical services; 103 km access road from port to plant site; Airport and heliports; and Communications and information systems. (Include flow diagram and 3D picture of the mine and plant) 6

Page 7 of 84 1.3.1 Expected work force and working conditions 1.3.1.1 Construction phase The construction phase will be divided in 3 phases: Pre-construction of road and port facilities expected start May 2011 Construction of port, pipeline and access road expected start October 2012 Construction of Processing plant and mine camp expected start 2013 The construction contracting strategy is to limit the number of contractors on site for ease of administration and supervision. There could be 3 (three) Civil and 2 (two) Mechanical and Electrical contractors. 1.3.1.2 OOperation Phase The total number of employees is expected to be between 500 and 600, whereas: Approximately 250 will work at the mine Approximately 120 will work at the processing plant Approximately 130 at the administration, Infrastructure and Harbour 40-45 at port and plant operation and maintenance 7

Page 8 of 84 The plant will work 24 hours a day, 365 days a year. No more than 300 employees will be at the time at the mine site. The workers are expected to be organised in shifts of 12 hours, with rotations schemes of 4 weeks in-4 weeks out, both at mine site and port. The staff at mine site will be transported to and from mine site by air (aircraft and helicopters), directly to Nuuk from mine airport or to country of residence via Mine airport in Kangerlussuaq. Some workers at port site may also be able to travel back and forward their town of residence in Greenland by boat. Deliverable of goods will be by boat/ship to the port site and further transported to the mine site by land. Preliminarily, work positions that are expected to be fulfilled with Greenlandic workers from year 1 are more likely to be in the mine camp, port site, air strip and road maintenance. It is unlikely that positions that require specific training and experience at the mine and processing plant can be completely filled by Greenlandic workers from year 1. A program for training and development of skills needs to be developed in order to gradually replace specialised foreign workers in these areas. The likely percentage of Greenlandic workforce at year 1 is 20 %, which is expected to duplicate after the first 5 years. There are no gender restrictions for any of the jobs. While proactive measures will be on place to promote recruitment of female workers, it is at the moment unknown how high a percentage of female staff is realistic to establish as target. 1.4 The SIA proces 1.4.1 Study team London Mining has commissioned Grontmij l Carl Bro to prepare the SIA for the project. The core project team will consist of experts with knowledge on Social Impact assessment from Mining activities, detailed knowledge on Greenland (language and culture), Mining activities, Communication and Facilitation of processes. Grontmij l Carl Bro will act as an independent consultant to conduct the SIA and facilitate stakeholder (including the public) involvement in the SIA process. External international and local experts will be involved for the analysis of especially significant topics and issues. Name Ana Gabriela Factor Tanja Nielsen Rikke Carlsen Heidi Hjorth Role Team Leader, SIA Mining Expert. Main responsibilities: Development of methodology, impact analysis and QA of reporting. Arctic Mining and SIA/EIA Expert. Main responsibilities: Baseline and field studies, communication with stakeholders. SIA Expert. Main responsibilities: Communication, facilitation, and preparation of the SIA report. SIA Expert, specialised in Corporate Social Responsibility and sustainability reporting. Main responsibility: Impact and benefit plan, 8

Page 9 of 84 monitoring and evaluation plans. 1.4.2 Approach to SIA The BMP SIA Guidelines of November 2009 is our basic reference to establish the minimum level of information, content, and general structure of the SIA. During the planning and development of the SIA process, other references will be used as best practices for SIA for the mining industry (International Council on Minerals and Metals, International Reporting Initiative for Extractive Industries) as well as knowledge and experience developed in Greenland to evaluate and assess the social conditions and impacts. The SIA will be based on a participatory approach, involving the stakeholders as much and effectively as possible at each stage of the SIA process. A high degree of communication will be promoted and implemented along the whole process. These objectives will be achieved by a policy of transparency, and a practice of clear and cultural sensitive means of communicating all relevant and required information as well as modern and state-of-the art participatory consultation and discussion techniques. The selection of socio-economic parameters for the baseline study will be based on the specific characteristics of the arctic living conditions. For the fieldwork information collection and consultations protocols specific to this project, the selected stakeholders and particularities of life and work in Greenland will be developed and implemented. 1.4.2.1 General Approach The general approach to the SIA is to focus on identifying potential relationships between the proposed potential impacts from the project and valued socio-economic components. The identification of potential relationship (negative impacts, benefits, indirect effects, etc.) will be based on the baseline study and the analysis of the project and its components and a checklist of critical questions addressing the key social issues. All relevant potential impacts will be identified and priority will be given to the ones which are identified as the biggest concerns by stakeholders and authorities. For the potential impacts identified, the SIA will include the evaluation of the impact (significance) and propose a possible mitigation. The net impact after the mitigation measure is applied will be further described. For the potential benefits identified, the SIA will also include the evaluation of such benefits and propose measures to maximise it. 9

Page 10 of 84 1.4.2.2 Approach to the scoping phase First step was to develop a checklist of relevant questions to be addressed in the SIA. This list was based on a number of documents, as the Guideline (BMP), Socio- Economic Impact Assessment Guideline (Mackenzie Valley) and Addressing the Social Dimensions of Private Sector Projects (International Finance Corporation - World Bank Group). Furthermore, Greenlandic research documents and studies such as SLiCA (Survey of Living Conditions in the Arctic) were used. Next step was to present this list and the preliminary results to the authorities and then to the selected stakeholders at a workshop, which was held on November 18, 2009. At the workshop the preliminary results and questions were discussed in groups. All stakeholders were invited to send further comments. Detailed comments and suggestions were received from the group discussion afterwards. Initial feedback from stakeholders can be found in Annex 1. This draft ToR is mainly based on the result of the initial scoping phase and the dialogue with the stakeholders, further updated in the light of the information provided by the PFS for the 10 MTPA report.. 1.4.3 Study area and temporal boundaries The study will cover the area directly impacted by the mining operations and ancillary facilities (port, road, railroad/pipeline, airport, etc.) and the towns and settlements where the impacts and benefits of employment, business opportunities and developments directly and indirectly created by the project are expected to be more noticeable. The primary area of influence will be Nuuk, Kapisillit and the surrounding areas. The secondary area of influence will be Kommuneqarfik Sermersooq in general. For the baseline study the information will be processed and analysed at three levels: National, Municipal (Sermersooq), and town/settlement (Nuuk and Kapisillit). The SIA will cover the following stages in the project: The construction stage The operational stage 1.5 Key social issues to be addressed in relation to the impacts of the project As a result of the scoping exercise and corresponding consultations and feedback, the main issues and key questions identified as critical are the following: Employment, human resources development, and business opportunities; Use of natural resources Livelihood and cultural change Working environment and health. Other social issues and key questions to be addressed during the SIA process are structured within the following themes: Changes in population/demographic Movements originated by the project 10

Page 11 of 84 Potential changes in business life/structure Potential impacts of the project on public services Potential social conflicts (competition for jobs, vulnerable groups, lifestyle and culture) Public health Cultural and natural values related to natural resources (fishing, hunting and tourism) Cumulative Impact with other development projects in the area The presented list of issues/questions and the priorities established were identified during the scoping exercise and further commented and completed by input by stakeholders and authorities. 1.6 Public participation and Stakeholder involvement 1.6.1 List of stakeholders For this project, the list of stakeholders identified and further completed during the consultations for the scoping phase is the following: Table 6.1 List of stakeholders English description - Danish names Authorities BMP- Råstofdirektoratet Government of Greenland - Departementer i Selvstyre: - Sundhed - Sociale anliggender - Fiskeri, fangst og landbrug - Erhverv og arbejdsmarked og Erhvervsuddannelser - Indenrigsanliggender, Natur og Miljø - Infrastruktur og trafik (Ejendoms- og Beredskabsstyrelsen) - Kultur, uddannelse, forskning og kirke - Departementet for Finanser Municipality - Sermersooq Kommune - Økonomi og Erhvervs forvaltning - Anlæg og Miljø forvaltning - Udviklingsforvaltning - Velfærdsforvaltning Nationalmuseet Kommunernes Landsforening Workers and employers organizations Arbejdernes Fagforening Grønlands Arbejdsgiverforening GA Arbejdsgiverforening Greenlandic names Aatsitassanut Ikummatissanullu Pisortaqarfik Naalakkersuisut - Peqqissutsimut Naalakkersuisoqarfik (PN) - Isumaginninnermut Naalakkersuisoqarfik (IIN) - Aalisarnermut, Piniarnermut Nunalerinermullu Naalakkersuisoqarfik (APNN) - Inuussutissarsiornermut Suliffeqarnermullu Naalakkersuisoqarfikk (ISN) - Nunamut namminermut, Pinngortitamut Avatangiisinullu Naalakkersuisoqarfik (NNPAN) - Ineqarnermut, Attaveqarnermut Angallannermullu Naalakkersuisoqarfik (IAAN) - Kultureqarnermut, Ilinniartitaanermut, Ilisimatusarnermut Ilageeqarnermullu Naalakkersuisoqarfik (KIIIN) - Aningaasaqarnermut Sulisoqarnermullu Aqutsisoqarfik Kommuneqarfik Sermersooq - Aningaasaqarneq Inuussutissarsiornermullu Pisortaqarfik - Sanarfinermut Avatangiisinullu Ingerlatsivik - Piorsaanermut Ingerlatsivik - Tungiunermut Ingerlatsivik Kalaallit Nunaata Katersugaasivia KANUKOKA Sulinermik Inuussutissarsiuteqartut Kattuffiat SIK Nunaqavisissut Suliffiutillit Kattuffiat (NUSUKA) 11

Akademikernes sammenslutning I Grønland Sygeplejerskernes fagforening Arbejdsformidling Arbejdstilsynet (Association of )ex-workers from Maarmorilik and Olivin mine contact via SIK Organizations related to business and development Grønlands Turist - og Erhvervsråd GTE Greenland Mining Service Nukissiorfiit, Grønlands Energi, vand og meselskab Arctic business network Entreprenør firma I Organizations related to education and trainning Mine- og entreprenørskolen Jern- og Metalskolen Grønlands Universitet Naturinstituttet Center for Arktisk Teknologi (DTU og Maniitsoq) NGO s and organizations of fishermen and hunters Naturforening ICC Fiskere og fangeres organisation. Nationalt og lokalt Rensdyrjægere Other civil society organizations Kvindeforening De ældres forening Organizations related to public health and vulnerable groups Departementet for Sundhed Væresteder Alkoholbehandlingscenter Kommuneqarfik Sermersooq Afdelingen for Sundhed og Forebyggelse Kapisillit Residents in Kapisillit and their organizations A/S INI Kalaallit Nunaanni Ilinniagaqartuut Kattuffiat Peqqissaasut Kattuffiat (PK) Piareersarfiit Sullivinnik Nakkutilliisoqarfik SIK Inussuk Sulisitsisut Greenland Mining Service Nukissiorfiit GNC Sanaartornermik Ilinniarfik or Sanilin (Sisimiut) Saviminilerinermik Ilinniarfik Ilisimatusarfik Pinngortitaleriffik AVATAQ Pinngortitaq avangisillu peqatigiiffik ICC Kalaallit Nunaanni Aalisartut Piniartullu Kattuffiat KNAPK, Aalisartut Piniartullu Peqatigiiffiat (APP) Tuttunniartartut Arnat Peqatigiiffiat Utoqqaat Peqatigiiffiat Peqqissutsimut Naalakkersuisoqarfik (PN) Inuuneritta/Paarisa Nanu Børn/Mælkebøtten/Pooruseq (handikappede)/utoqqaat peqatigiiffiat Qaqiffik Kommuneqarfik Sermersooq Peqqinneq pitsaaliunerlu A/S INI Page 12 of 84 Key Informants Inuit, Saami and the Indigenous Peoples of Chukotka (SLICA) Statens Institut for Folkesundhed 1.6.2 Proposed Stakeholder involvement during the SIA Process SIA Phase Stakeholder Objective of the involvement Proposed dates 12

Page 13 of 84 Scoping and ToRs List of participants (see annex 1) Objective of the stakeholder workshop: - Inform about the project and answer questions; - Present the SIA process; - Present the proposed scope (geographic scope, key issues, recommended baseline studies, sources of information); - Identify gaps, weaknesses and/or redundancies in the proposed scope; - Clarify contact persons; - Identify key informants and sources of secondary information for the baseline study (particularly about Nuuk, Kapisillit and Atammik); - Establish a forum with involved stakeholders and start bilateral dialogues; 18 November, 2009 in Nuuk Baseline study Authorities and key- informants Qualitative methods: Collection of primary information from key informants and authorities: Objective is to collect information for the baseline study which is not available from the secondary sources or need to be confirmed/up-dated. November 2010 Focus groups and key informants (see stakeholders list) I formation from stakeholders and groups of interest. The objective is to collect information and perceptions (fears, expectations, etc), from specific groups (focus groups) of stakeholders that are relevant for the project. Identification of vulnerable groups. Description of the involved organizations and understanding of their role in relation of the project November 2010 Baseline (Quantitative methods: Communities of Nuuk and Kapisillit. Objective is to generate data at household level for the baseline study. November 2010 March 2011 SIA Phase Stakeholder Objective of the involvement Proposed dates Development of draft Benefit and Impact Plan Development of monitoring 1 and evaluation 2 plans Selected groups of interest related to the implementation of benefit and impact areas BMP Selected partner(s) for each specific program Objective is a participatory identification of potential main areas of impact and benefit, and participatory development, design and implementation of plans and programme for the BIP. Objective is to define how to monitor and evaluate the benefit and impact plans, to define the role of the stakeholders and design tools and programs for monitoring and evaluation November 2010 -August 2011 January -August 2011 1 Monitoring: ongoing, methodical collection and analysis of data on development activities, which provides program managers and stakeholders with early indications of progress and achievements of goals. Monitoring often measures output and is undertaken more often than evaluation. Often done by people involved in the program. 2 Evaluation: Primarily concerned with longer-term results of development activities, or the measurement of outcomes/impacts. It aims to identify how and why activities succeeded, failed or where changed to improve effectiveness. Evaluations can be done periodically by independent, external advisors, but self-evaluation can be very useful. 13

Page 14 of 84 Disclosure of Draft SIA Report and Public Hearing Disclosure of Draft SIA Report and Public Hearing BMP List of stakeholders (table 1) General Public Objective is to present and discuss an early draft version. Objective is to present, clarify, validate and receive feedback on the findings of the impact analysis, recommendations and draft Benefit &Impact Plan. From submission of SIA. September 2011- October 2011 14

Page 15 of 84 1.7 SIA methodologies 1.7.1 Baseline study The baseline study will provide information on demographic, economic conditions and trends, political structures, local organisations, cultural traits, and other factors that can influence the way in which affected communities will respond to anticipated changes brought about the projects. The baseline also helps to predict in which way the project will be affected by these factors. The development of the baseline and the identification of the impacts are an interrelated and parallel process. When the critical issues have been identified it is possible to design detailed studies on specific groups (focus groups) affected by the project. The baseline study will be based on review of secondary resources and information obtained through qualitative, quantitative, and participatory methods. The scope of the baseline study is based on identification of a number of themes which is considered important. The identification is developed based on the BMP Guidelines, SLiCA study (2006) and the note from IFC. For each theme and subtheme the SIA team has considered how the information will be organised and analysed. 1.7.2 Data collection and research from secondary data First step in the baseline study is to review the information available from secondary sources. The secondary sources are official data about Greenland, Nuuk and the area of Isua. Furthermore research reports and other relevant reports and studies will support the creation of the starting point of the baseline study. 1.7.3 Data collection and research from primary sources The data collection and research from primary sources will contain both qualitative and quantitative methods. The SIA team will elaborate specific interview questionnaires and tools for qualitative methods which will be based on international standards, local experience and specific objectives and scope of the Isua Iron project SIA. International experts will ensure scientifically sound and robust methodologies and tools. Greenlandic experts will be responsible for ensuring local sensitivity and adequacy. All tools will be tested before undertaking the overall survey activities. 1.7.3.1 Qualitative methods Qualitative methods have to do with people s perceptions, how they view themselves and the world around them. A iety of techniques will be used depending on the complexity and size of the community. 15

Page 16 of 84 For larger groups, group meetings and group interview will be used. Focus group meetings and group interviews will be used for smaller groups which represents a larger group. Focus group discussions will be used providing information on key issues from stakeholder representatives. For these focus group discussions, interview guides and participatory techniques will be used for the collection of information, opinion and perceptions Individual interviews with knowledgeable key informants will be used to collect information and get a better understanding on complex issues and past events. Information to be collected from focus groups by qualitative methods: Land and natural resources use Livelihood and cultural change Public health and vulnerable groups Business opportunities Family budget and consumption/expenditure patterns 1.7.3.2 Quantitative methods The quantitative methods will be used to generate data, mostly at household level and for selected artic living conditions indicators, when such information can not be found or calculated from secondary sources, or needs to be updated. Existing high quality, recent research studies like the SLiCA (Survey of Living Conditions in the Artic) study Mobility Study in Greenland, 2010, will be used as main references. Quantitative collection of data will be compatible with such studies. The need of specific quantitative studies will be further evaluated after completing the first draft of the baseline study. 1.7.3.3 Strategic Impact Analysis Synergies and conflicts with other projects in the area will be evaluated: competition for human resources, competition for use of existing services, access to natural resources, business opportunities. Synergies and conflicts with other mining projects in Greenland, particularly in terms of education and development of human resources will be also included in the analysis. 1.7.4 Impact Analysis Methodologies The positive and negative impacts of the project activities on valued socio-economic components, both during the construction and operation phases, will be predicted and its magnitude quantified as far as possible using an Impact Matrix. The significance of the impacts identified will be evaluated according to the following significance factors: Certainty of impacts: likelihood of occurrence, level of certainty of its occurrence Extension of the impacts: geographical range of the impacts, regional winners and loosers? 16

Page 17 of 84 Duration and frequency of impacts: temporary occurrence of the impacts, (short lasting or permanent?), wide fluctuations that could disrupt the community over time (boom-and bust periods) Period of Manifestation: the impacts could be noticed immediately or over time by the community The public concern will also be considered when assessing the significance of the impacts. Mitigation measures will be identified for all impacts likely to occur, adverse in nature and significant enough to require mitigation (medium and high-level (negative) impacts) in order to mitigate or eliminate such impacts. 1.8 Reporting format of SIA report According to the Guidelines, the final SIA report has to be submitted to BMP in Greenlandic, English and Danish. The Table of Content for the SIA Report for the Isua project will be elaborated as per Guidelines, unless otherwise agreed between the consultants and BMP: Front page Executive summary Definitions and abbreviations Introduction Policy, legal and administrative framework Project description Methodologies Description of the social baseline conditions Potential impacts Analysis of alternatives Maximization of development opportunities and mitigating negative impacts Benefit and Impact Plan Monitoring Plan Evaluation Plan Public participation Appendices 17

Page 18 of 84 1.9 SIA time schedule The time table below is tentative and based on the current available information. SIA Phase Time period Comments and public participation activities Scoping and development of draft ToR 3 November 2009 October 2010 Final ToR Public release of ToR October 2010 Baseline Conditions February 2010 - January 2011 Consultation held in November 2009. Due to project changes from 5 million tonnes per year to 10 million tonnes per year the scoping has been awaiting an updated version of the pre-feasibility study. Information meetings for authorities and stakeholders. Impact Analysis February May 2010 Benefit, Impact and February 2011 Monitoring Plan August 2011 Formal submission of August 2011 final draft SIA Public hearing and consultations of SIA September 2011 October 2011 Final SIA November 2011 Benefit and Impact and November 2011 Benefit Agreement December 2011 Final IBA Collection of Information from primary sources, interviews and focus groups in Nuuk and Kapisillit November 2010. Includes consultation with selected stakeholders in Nuuk and Kapisillit.. Public Hearing activities to be held in Nuuk and Kapisillit. 1.10 Recommendations 1.10.1 Recommendations for project design Based on the scoping exercise and the feedback from the stakeholders it is recommended to London Mining Greenland a/s to evaluate the following proposals: During the consultation the issue of ensuring protecting of aquatic mammals and fish was repeatedly stressed so it is recommended to pay attention to this in the EIA. It is also recommended to involve the stakeholders in the development and implementation of the monitoring plan. 3. 18