I had a chance to talk with both Dionne and Philippe later this afternoon and they both had agreed that if the bulk sampling portion of the project did not require any water use and there was no deposit of waste, then this activity did not need to be included under the scope of the water licence and should be considered under other Land Use Approvals (although you had mentioned that NIRB hadn't completed their screening at this time). A letter should be forthcoming just as formality, however the email server for the NWB is being temperamental and not allowing any emails with attachments to go through for whatever reason, so getting the letter in for review and distribution might take a bit of time.

I note that the Licence application did not make mention of the bulk sampling, nor did the questionnaire. If you could ensure that the questionnaire you were going to revise covers all other aspects of the project, that would be great. The inclusion of the bulk sampling should remain a part of the project description though, so that everyone is aware of that part of the project, however it should not influence the outcome of the reviews. An please emphasize the no water use/waste disposal. Once this information is received, there will still be a 30 review/comment period required, but at least True North should be able to proceed with the portion of the project that appears will be the most time consuming to complete.