Socioeconomic cost analysis deficient. Do not approve this project

I have three specific comments and a personal statement.

 

1. Section 6.16 of the EIS Summary addressing the Socioeconomic Valued Component takes up less than 1 page of this massive document. The assertion of economic benefit is vague and without numeric quantification. The analysis is summarised in Section 6.16.2 as:

"Positive socio-economic impacts are associated with the Project, including long-term employment gain and/or sustained activity within the area. All phases of the Project will provide employment opportunities for local residents and Indigenous Peoples, as well as provide tax revenue for the municipal, provincial, and federal levels of government. Indirect employment will be generated by the Project through the use of external contractors and suppliers."

These claims are meaningless without substantiation; the proponent should be required to provide detailed numeric calculations and analytical evidence supporting their statements. 

 

2. The entire Section 3 on alternate means of carrying out the project is flawed in that it only takes into consideration what is economically feasible for the proponent and their concerns. It does not evaluate what is in the best interests of Nova Scotians.  For example in Table 3.2.1 remewable energy sources for powering operations is concluded as technically feasible but not economically feasible.  Given the provincial interest and  societal priority given to climmate change and GHG emmission reduction the proponent should be required to use 100% renewable energy and an analysis of other conflicts with corporate and societal interests presented in this section should be conducted.

 

3. A further problem with the meager socioeconomic assessment submitted by the proponent is not including the value provided by wilderness and ecosystems as a VC.  Natural Capital needs to be included as a socioeconomic component and an assessment conducted of the impact of the proposed project on the Natural Capital Value of the proposed project area.   

This proponent like all mining companies, would have us believe the purported benefits outwiegh the costs.  They have the arrogance to describe the economic benefits in one brief vague paragraph and to dismiss potentially more beneficial approaches because they are deemed to be not economically feasible for them. They have the audacity to claim they can do their business without harming the environment at the same time as they face, and continue to evade court dates, for 32 environmental charges. 

The benefits they tout are short term but the damage they cause can last forever.  There is a saying common in West Virginia mining country that goes… “what we do to our environment we do to ourselves.”  We know what human and environmental devastation looks like in Appalachia;  please make sure that it doesn't come to pass in Nova Scotia by rejecting the Beaver Dam Mine Project.

sincerely, John Perkins