Feedback on Beaver Dam Mine Project

Creating open-pit gold mines, with tailings deposits, in proximity to our river systems and important habitats is extremely concerning. Of relevance, the Nova Scotia Provincial Auditor General Michael Pickup published a report in late 2017, indicating a failure in the government monitoring and enforcement of industrial projects to ensure they comply with their environmental terms. There have been several NS AG reports since then, highlighting the same issue.  Without proper oversight, and given that Atlantic Gold / St. Barbara already has had 32 environmental charges laid against it earlier in 2021, we need to be very careful. Furthermore, St. Barbara operations at their other international sites, Papua New Guinea and Solomon Islands appear to have had significant environmental issues and community concerns over the past 10 years, and the company performance at their other operations should be considered as part of the reliability assessment.  With all this in mind, here are some specific comments regarding this proposal at Beaver Dam:

• Gold mining has some of the largest human and environmental impacts (https://www.google.com/url?q=https://miningwatch.ca/blog/2019/2/5/gold-facts.&sa=D&source=editors&ust=1639627514276000&usg=AOvVaw1AEsYMYIiJssF3lsRGPeqr) of all types of metal mining.
• It is my understanding that Millbrook First Nation have submitted a formal opposition (https://www.google.com/url?q=https://iaac-aeic.gc.ca/050/evaluations/proj/80111/contributions/id/55794&sa=D&source=editors&ust=1639627514276000&usg=AOvVaw0HoXKjl_3MrpNimzvY4a5N) – they fear for their health, their livelihoods, and their way of life.

Roads & Transportation:

• Proposed haul road (https://www.google.com/url?q=https://iaac-aeic.gc.ca/050/documents/p80111/141940E.pdf&sa=D&source=editors&ust=1639627514277000&usg=AOvVaw3lODu9n9EQdP72QfD9HEfw) (2.3.2) now punches through forest and wetlands, disturbing and destroying wildlife habitat (including endangered mainland moose (https://www.google.com/url?q=https://novascotia.ca/natr/wildlife/biodiversity/pdf/recoveryplans/mainlandmooserecoveryplan.pdf&sa=D&source=editors&ust=1639627514277000&usg=AOvVaw3YaZEy9IVBhfCf0Cqca7lA)) and wilderness.

• The approximate disturbance area of the Haul Roads is 25 ha and bypass roads are expected to disturb approximately 10 ha, with a total disturbance area of 35 ha, of which 10 ha, or 30% is on crown land.
• One of four segments of haul road: 10.7 km Mooseland Road that will be upgraded by Department of Transportation and Infrastructure Renewal (TIR) (the taxpayers of Nova Scotia presumably pay for this)
• It may be necessary to use the Public Roads during start-up (i.e., 6 to 8 months) 

• The 31km haul road proposed to connect Beaver Dam with Touquoy processing will be used 190 times per day for 16 hours each day, for 350 days a year, for 5 years.
• A large truck will pass by every 2 and a half minutes (https://www.google.com/url?q=https://www.halifaxexaminer.ca/environment/nova-scotia-has-laid-charges-for-32-environmental-infractions-against-atlantic-gold/&sa=D&source=editors&ust=1639627514278000&usg=AOvVaw3KlMWwIfBYx4fMd_3XUPBX) between 7am and 11pm, every day.
• By-pass roads crossing and parking area is currently being considered in the design to address safety concerns by local residents.

Direct Concerns re: Environmental Impacts

• Nova Scotia Salmon Association’s 17-year acid mitigation program (https://www.google.com/url?q=https://www.nssalmon.ca/acid-rain-mitigation&sa=D&source=editors&ust=1639627514279000&usg=AOvVaw0RH89WI5EiDyc9v7Mya8r-) will be largely undone
• The 31 hectare pit, reaching 175-200m depth is appears to be planned to be located only 50 metres from Killag River (https://www.google.com/url?q=https://mailchi.mp/nssalmon/your-nova-scotia-salmon-association-10697128?e%3D161b5fffb3.&sa=D&source=editors&ust=1639627514280000&usg=AOvVaw1lM88c_aAFjYiM5U-4_oU_).  This is unacceptable, there needs to be some sort of minimum perimiter instituted that keeps large industrial operations and tailings ponds away from our rivers and sensitive habitats.
• The federal departments that monitor and regulate the industry are in the process of addressing shortcomings (https://www.google.com/url?q=https://www.oag-bvg.gc.ca/internet/English/parl_cesd_201904_02_e_43308.html%23p74.&sa=D&source=editors&ust=1639627514280000&usg=AOvVaw1ki7gddyfblOJGozfYuy6Z) in their effectiveness to protect fish and their habitat from mining effluent
• The ore transportation between the two sites also introduces a risk of contamination for waterways along the route and heavy metal dust pollution.
• This Meguma Terrane rock formation will be exposed and crushed releasing acid-forming sulphide compounds which when oxidized create sulphuric acid leading to Metal Leaching & Acid Rock Drainage (https://www.google.com/url?q=https://novascotia.ca/natr/meb/hazard-assessment/acid-rock-drainage.asp&sa=D&source=editors&ust=1639627514281000&usg=AOvVaw3cTLsaCN-aWanmoFMbNkIc)
• There is no report on the cumulative effects of putting multiple mine site tailings into the proposed spent pit at Touquoy.
• There are wetlands of significant concern that will be destroyed. Wetlands serve many important ecological functions.
• The project will clearly cause deforestation and land degradation that the Review's approval would be inconsistent with Canada's position and the federal government's endorsement of most recent commitments under the Glasgow Leaders Declaration on Forests and Land Use (https://www.google.com/url?q=https://ukcop26.org/glasgow-leaders-declaration-on-forests-and-land-use/&sa=D&source=editors&ust=1639627514282000&usg=AOvVaw1fNiHuazXsofzhJENCd4Sn) on November 2nd

Also, 10 years of post project monitoring is described.  However, the tailings will exist forever. Nothing lasts forever, we can be certain that at some point in our future these tailings ponds will destabilize, whether that is in 20 years, 200 years, or beyond. There are over 300 documeted tailings breaches and many of thee examples have become profound environmental disasters.  The 10 year monitoring doesn't cover a tiny fraction of lifespan that the tailings would exist in a harmful state.   Suggest instead the requirement that industrial activities do not leave behind large quantites of environmentally harmful waste.