Submission on Beaver Dam Mine - Technical report highlighting concerns regarding collection of baseline data, scope of assessment, and significance of predictions

Please see the attached file for the complete report. The covering letter is reproduced below.

Enclosed past this covering letter is a report for consideration by the Impact Assessment Agency of Canada, the Atlantic Mining NS Corp (AMNS), and federal authorities in your ongoing assessment of the Beaver Dam Mine Project (henceforth ‘the Project’).

These recommendations were prepared by graduate students and their professor as part of coursework for the class ENVI5001 Environmental Assessment at Dalhousie University. All the authors have been trained in the governance, substantive components, and procedural components of federal impact assessment. We bring post-graduate degrees in environmental studies and sciences and cumulative decades of work experience in environmental consulting, research, and management, and lived experience in the resource industry and frontier communities. We have analyzed Valued Components and procedural elements associated with the Beaver Dam Mine EIS and raise concerns with the quality and scope of data collection and the feasibility and adequacy of proposed mitigation measures. We present in this covering letter a summary of our recommendations with a full analytical report to follow.

Summary of recommendations

Air quality

• The baseline levels for CO₂, CO, SO₂, NO₂, NO, NO_x and PM in the Beaver Dam site and the haul road need to be clearly identified. It is recommended that they collect data for a period of at least one year these greenhouse gases to establish a proper baseline so that the impact from the project can be gauged accurately.
• The statement that no additional GHGs emissions will be caused during the processing of the Beaver Dam mine ore at the Touquoy facility should be supported with evidence.

Surface water quantity and quality

• The location of the open pit mine should be changed so that is further away from the Killag River. Underground mining activities and blasting for ore can cause fractures which could cause the river to drain into the mine pit and the cause harm to the ecosystem downstream.
• Evidence is needed to support the statement that the project impact on the Killag River is negligible. The baseline study of the watershed revealed already elevated levels of heavy metals. A thorough study needs to be conducted to properly gauge the impact that effluent discharge will have on the watershed.

Workforce development

• The Proponent should implement social life cycle assessment to determine if occupational stressors from the Project may influence the local community’s livelihoods after mine closure.
• Corporate social responsibility needs to be considered by applying global corporate standards to ensure equitable workforce development and sustainable mining operation. 
• The EIS lacks discussion of how the LGBTQ2S+ (Lesbian, Gay, Bisexual, Transgender, Queer or Questioning and Two-Spirit) and Indigenous community is represented in, and engaged by, the mining sector. It is recommended that the Proponent apply Gender-Based Analysis plus (GBA+) initiatives to be more inclusive of minorities in the hiring process.

Community health and safety

• AMNS is strongly urged to ensure the Employee Assistance Program is integrated into employee training programs to raise awareness of mental health disorders, reduce substance abuse, and destigmatize mental illnesses in the mining sector. 
• We recommend conducting a Health Impact Assessment HIA to address potential impacts on the local and Indigenous communities’ physical, mental, and social health. 
• Mining operations often involve movement of people and goods; therefore, the Proponent should detail how they will follow provincial health mandates to ensure that mining operations do not contribute to COVID-19 outbreaks.
• Prior to development, further evaluate flood risks and catchment area flow capacities to ensure staging areas are outside of flood prone areas, flood proof electrical distribution components and re-evaluate haul road ditches for adequate run-off capacity.
• Implement seasonal monitoring programmes for groundwater levels which pre-plan for drought scenarios. Engage in surrounding community with planning and results.
• Each year, conduct seasonal education programming and weekly health surveillance monitoring for worker safety during extreme heat and cold conditions.

Species at risk and wildlife

• Efficient reporting of fish habitat alteration or possible leeching of containments into the water bodies must be tested regularly for water quality assessments to ensure toxic levels of minerals are not harming the fish populations.
• Soil tests must be completed during all phases of the mine lifespan to ensure that containments do not leach from soil to the water creating toxic environments for fish.
• Specify the speed limit for vehicles on roadways with potential snapping turtle presence and make sure that all on-site personnel are educated in spotting them on the road. Introduce a combination of speed limit signs and speed bumps to manage speeding, and indicate if the speed limit of these zones will be adjusted at times with limited visibility such as during the night, rain, or fog. 
• Implement a thorough risk plan associated with the potential of the workers being bitten while handling a snapping turtle on the road. There should be more emphasis in the appendix on what not to do when handling turtles.
• Specifications on buffer zones should be included in the proponent’s impact assessment. Road buffers should either consist of 1.5m of extra pavement or a strip of vegetation added on the road shoulders to deter snapping turtles from nesting there. This would reduce the risks of snapping turtle mortalities and nest destruction, while not being environmentally destructive in its implementation, especially if the proponent opts to use a vegetative road buffer.
• Provide a detailed outline and steps that the on-site workers can follow and learn of what to do if a moose is spotted near or on the road.
• Indicate specifically where the fencing is planned to be implemented and how far it will extend in the Beaver Dam Site. It would be most beneficial to present a map depicting all the proposed areas that plan to have fencing and display the sightings/observations of moose tracks to have an effective layout of the fences.
• Inclusion of customizable Raspberry Pi nesting cameras for additional monitoring during the construction phase (but not exclusively) in areas where ground-nesting species, such as bank swallows and common nighthawks, have established.
• Inclusion of additional spring migration monitoring information concerning the point survey areas and logistics. The 2014 spring migration point count consisted of only 12 points and had a slightly larger number of species in comparison to the 2015 fall migration point count at 32 points. 
• For improved scientific transparency, the proponent should include the results of baseline fish habitat studies for all spatial areas where mining activities will occur. Additionally, a more recent baseline fish and fish habitat survey should be conducted within the Touquoy Site since environmental conditions may have changed since original assessment in 2007.
• Conduct field surveys to sample for priority invertebrate species in the project area during the most appropriate times of the year to gauge their presence.
• Increase monitoring and decontamination of equipment for invasive species. Mitigation for invasive species is currently considered; however, the use of decontamination spray(s) on the underside of equipment used near areas with potential exposure opportunities will assist in reducing the risk of introducing invasive species that may outcompete the  Species of Conservation Interest (SOCI) and Species at Risk (SAR) populations.

Wetlands and lichens

• Increase the size of wetland vegetation monitoring plots from 5x5m to at least 10x10m and ensure that there are 40 survey plots for accurate vegetation identification and assessment.
• Identify all wetland functions that will be lost due to project activity in the Wetland Compensation Plan and provide the measures that will offset these losses.
• Include in the Wetland Compensation Plan considerations for wetland habitat restoration of all potentially impacted species at risk identified in the EIS.
• Provide a list of wetland restoration monitoring indicators in the Wetland Compensation Plan to help estimate possible monitoring timelines and the required resources to fulfill wetland restoration obligations.
• The setback distance for Blue Felt Lichen occurrences along those portions of the Haul Road should be increased based on the relevant literature.

Terrain, soil and parks

• The proponent should purchase land equivalent to double the area they intend to disturb for the sole purpose of protection under the Wilderness Areas Protection Act or the Special Places Protection Act.
• The Proponent should acquire more data on Parks and Open Spaces, including air quality surveys, wildlife (wildlife species, composition, abundance, and habitats), vegetation (plant species, composition, abundance, and percent cover of each vegetation stratum), and land type inventories representative of each ecosite in each Provincially Designated Area within the Local Assessment Area’s (LAA) and assess Park and Open Spaces’ vulnerability to direct and indirect impacts based on newly collected data.
• The Proponent should practice more frequent, periodic forest field surveys either annually or biannually to account for forest changes or discrepancies and integrate a combination of independent datasets and geospatial data (e.g., Landsat Forest cover imagery, NSL&F Forest Inventory), novel aerial reconnaissance surveys, and ground-truthing field-based methods for more robust forest assessments.
• More transparency should be incorporated in EIS baseline condition assessments with detailed descriptions of the timeline, methods, and steps used to reach the baseline condition.

Spatial boundaries

• Spatial boundaries for cumulative effects assessment (CEA), by definition, should expand beyond effects of a single action or local area. The proponent should provide defensible scientific rationale for the designated spatial boundaries used in the CEA.

The remainder of the document reports on valued components and procedural aspects the EIS, each analysis, recommendations, and supporting citations. The full document may be cited as:

Westwood, A., Doucet, T., Fequet, L., Ho, I., MacLean, N., MacNeil, B., Nguyen, P., Sharan, R., Thapar, K., Thurston, E., Vail, C. 2021. Submission on concerns and recommendations related to the proposed Beaver Dam Mine project in Marinette, Nova Scotia. Prepared for the Impact Assessment Agency of Canada. 110pp.

All coauthors consent to the public release of our work. Dr. A. Westwood, as the principal investigator and course instructor, certifies the technical soundness of the analysis and recommendations herein. Ms. Gianina Giacosa Massa supported the preparation and compilation of this report.

Thank you for your consideration, and we hope our recommendations (in the enclosed technical report) can support a project and impact assessment (IA) process which is more technically sound, just, and supports long-term environmental and economic prosperity in Nova Scotia.

Dr. Alana Westwood (on behalf of the coauthors)

Assistant Professor, School for Resource and Environmental Studies

Faculty of Management, Dalhousie University, K'jipuktuk (Halifax)

Direct inquiries to a.westwood@dal.ca (mailto:a.westwood@dal.ca)