I do not support the proposed Beaver Dam Gold Mine

Please accept this letter as confirmation that I oppose the proposed Beaver Dam Mine Project, as outlined in the revised Environmental Impact Statement (EIS). I fully support and echo the comments and concerns outlined by the Nova Scotia Salmon Association. In addition, here is a short list of some additional concerns to be emphasized:

• I am concerned that the certain impacts to West River Restoration Project run by the Nova Scotia Salmon Association and partners are not being adequately considered. Such certain impacts include:
  • Warming of the Killag River and Tent Brook – both important coolwater streams
  • Interruption of data continuity for the 17-year long research project. These data, such as water quality, electrofishing, temperature, and others will be rendered less valuable and less suited to long-term monitoring research. 
  • Burying of forested lands that are the critical headwaters of the watershed and where a large effort has occurred to restored these lands via catchment liming. These efforts have been funded by partnerships between all levels of gov’t, charity groups, private investment, and other fundraising.
  • Operation of the Killag River lime doser. Changes to the access road, river flow and water quality will ultimately impact how the NSSA operates its critical infrastructure, potentially at additional cost to this charity group.
• I am also concerned about the potential impacts to West River Restoration Project run by the Nova Scotia Salmon Association and partners are not being adequately considered. Such potential impacts include:
  • Unintended dewatering of the Killag River by the open quarry pit. Despite the best availably modelling, it is not possible to eliminate the possibility that the section of the Killag River immediately upstream from the NSSA’s Killag Lime doser will not become a ‘losing section’ where water is drained from the river and enters the pit. If large enough, the resulting loss of flow downstream could be catastrophic.
  • Introduction of sediment and poor-quality water to Killag River, Tent Brook and other catchments. The increased use of roads, expansion of roads, general disturbance of the sloped land and management of mine water via tailings ponds all have the possibility to introduce sediment and poor-quality water to the watershed. The success of the NSSA’s restoration project is largely attributable to improved water quality.
• In addition to the potential impact on aquatic species of concern such as Atlantic Salmon and American Eel, there are also many terrestrial species that will be impacted, not the least of which is endangered mainland moose. I have personally observed moose tracks,  scat and browse along the Beaver Dam Mines Road, each time reporting these observations to the NS Department of Natural Resources and Renewables. The proposed enormous volume of heavy machine traffic along this road would, in the worst case have acute effects on moose (e.g. death from collision), and in the best case have sub-lethal effects such as displacing moose from the high-quality habitat in this area or interrupting migration corridors and fragmenting habitat.
• Other terrestrial species that are likely to be impacts are:
  • Little brown bats. These were formerly common prior to white-nose syndrome, however small numbers of bats remain in this area,
  • Snapping turtles. These occur in the many small lakes and broadly in the Tent Brook, Paul Brook, Killag River, West River, Little River and other nearby watersheds.
  • Eastern whip-poor-will. I have personally observed a nesting pair located on an abandoned side road near Keef Brook (near corner of Lake Dan road and BDM road. This area has recently been restored via catchment liming. This area will be consumed by the expansion of the haul road.
  • Nighthawks. It is common to observe nighthawks foraging on mayfly or caddisfly hatches along the West River where the Beaver Dam Mines Road crosses. Heavy traffic, particularly during crepuscular periods will either displace these animals or lead to collisions and mortality.
• I am concerned about the impact that excavation and road construction will have on wetlands and groundwater. Specifically, the interruption of subsurface flows and the resulting hyporheic connectivity with surface waters. Many roads in the upland region of the eastern shore bisect groundwater and divert this flow away from its original path. This influences the recruitment of supply water for wetlands and streams. Only surface water is being considered in the EIS, not subsurface flows, despite their importance to forests, wetlands and freshwater streams.
• The societal impacts in the EIS are poorly weighted. Fishing, hunting, furharvesting, berry picking, and other activities by First Nations and non-indigenous Nova Scotians are extensive in this area and are not being adequately valued.
• This proposed work will be carbon intensive. This aspect of the work is poorly described in EIS, with minimal discussion on how to minimize carbon emmisions and no discussion of potential carbon offsetting commitments. Gold mining, and particularly this gold mine with low royalties, is one of the most financially lucrative industries. It should be held accountable for its contribution toward climate change and be forced to both reduce carbon emission and offset carbon emmissions.
• Atlantic Gold has a poor track record of accountability and environment compliance and will prioritize protection profit over protection of the environment and the West River Restoration Project.

In closing I am strongly against the proposed Beaver Dam Mine project. The West River watershed and the adjacent sub-watersheds are valuable and vulnerable resources that need our constant protection.  I hope that this opportunity to reset the path for Nova Scotia towards a more sustainable future is not lost. I stand in solidarity with the many conservation associations, concerned individuals and the Mi’kmaq of Nova Scotia in opposition to this proposal.

Sincerely

Edmund A. Halfyard