Concerns on proposed mine at Beaver Dam

Thank you for the opportunity to make public comments on this matter.
'Boom and bust" extractive industries such as hard rock mining can not be permitted as "sustainable" development. No where in the world do current mining practices typically reflect the spirit of the provinces Sustainable Development Goals Act. Gold mining is not acceptable new economic development with understanding of pressing climate related issues.
 I question streamlined for industrial ease of access provincial and federal permitting\monitoring\regulatory process's ability to prevent environmental and social devastation evidently caused by mining activity elsewhere in the world from happening in here. The applicant in this proposal is still facing 32 allegations of environmental infractions at their Touqouy mine.
This inability to adequately regulate and monitor industry is also evidenced globally by multitudes of contaminated abandoned mine sites , air\water pollution prevailing around modern mines and continued poverty of many rural areas negatively affected despite industrial promises of wealth. Environmental and human rights laws have provided little actual protections. (See attachment #1)
" Acid mine drainage and associated weathering products commonly result in physical, chemical and biological impairment of surface water. Pre-mine characterization of the risk of AMD formation is often inaccurate leading to notable post-mine risk to fisheries. Fisheries have been impaired world-wide by releases of AMD from mining areas. The mining industry has spent large amounts of money to prevent, mitigate, control and otherwise stop the release of AMD using the best available technologies, yet AMD remains as one the greatest environmental liabilities associated with mining, especially in pristine environments with economically and ecologically valuable natural resources. Problematic to the long-term operation of large scale metal mines is recognition that no hard rock surface mines exist today that can demonstrate that AMD can be stopped once it occurs on a large scale. Evidence from literature and field observations suggests that permitting large scale surface mining in sulfide-hosted rock with the expectation that no degradation of surface water will result due to acid generation imparts a substantial and unquantifiable risk to water quality and fisheries." (See attachment #2)
 The third national assessment of environmental effects monitoring data from metal mines: executive summary states ..."The Metal Mining Effluent Regulations (MMER) came into force in 2002 under the Fisheries Act. They prescribe end-of-pipe (discharge) limits for specified substances, and provide a national standard that is intended to protect fish, fish habitat and the use of fisheries resources ...
Almost all mines (57/62 or 92%) with confirmed effects observed at least one effect of a magnitude that may be indicative of a higher risk to the environment
Of the 26 mines that had completed IOC studies, 77% (20/26) identified current mine effluent as a primary or possible contributing cause of effects."   1.

Overall Conclusions of the Report of the Auditor General of NS on Contaminated Sites...
•  The Province does not have a coordinated approach to assess and manage risks for the contaminated sites it is responsible for.
•  The Province has a process to ensure it identifies the contaminated sites it is responsible for; however, there are weaknesses in monitoring.
•  The Department of Environment did not implement all  recommendations  from  the  June  2010 Management of Contaminated Sites audit."  2.

Beaver Dam, Fifteen Mile Stream and Cochrane Hill areas are known historical mining sites. As such, all proposed sites are already contaminated (to some publicly unknown state) and these abandoned wastes are continually contributing acid mine damage to surrounding watersheds in varying extents. Acid rain has seemingly become scapegoat in the province since it's discovery as an issue of environmental concern, but is not the only acidifying factor endangering the health of rivers. Beaches all along the eastern shore have been closed for shellfish harvesting since 2018 due to high mercury content with little public association made to the reasons. Lobster and tuna is consumed worldwide in increasing numbers without a mercury label warning attached. Marine Land recently has reconsidered releasing retiring whales in Nova Scotia into such a "polluted" sanctuary. Makes me wonder if it safe to let children build sand castles at any of these astoundingly beautiful beaches, or to go for a barefoot walk with my dogs.
Lime dosing and other important work done by local river associations to improve conditions for salmon should not be negated by heavy industrialization of the perhaps albeit not so "pristine habitat" that anglers make comment for the Agency to protect from development.    Lime reduces PH but does not reduce mercury or other heavy metal content in surface waters passing through disturbed contaminated sediments along riparian zones, however. This fact needs to be addressed in provincial waters if actual remediation of impacted rivers and beaches is to be realized. Sooner the better.
The province appears economically unprepared for the costs associated with now identified historically contaminated mine sites and industrial "partners" in very badly contaminated sites may be considered beneficial to the budget in addressing the situation. 3.
Reverting costs from the Crown and effected private landowners back to the industry that originally polluted and abandoned it's past liability is an understandable pursuit, but permitting the expansion of even larger environmental and health risks through proposed "modern" open pit mines and massive tailings facilities will not leave the province richer or healthier, but burdened with large lakes of toxic waste into perpetuity. Historical wastes are better to be phyto-logically, biologically and microbially remediated in constructed wetlands. Please make reference to footnoted studies referring to alternative to re-mining remediation treatments of contaminated sites.    4. 5. 6. 7. 8. 9. 10. 11.
Despite the dismal repeated history of abandoned mines and related water quality concerns across the country "Canada’s tax regimes for mining are among the most competitive in the world and reflect the realities of provincial ownership and royalties, high risk, and capital intensity, as well as a conscious decision by government to encourage this industrial activity. There are several tax provisions to support companies and investors in the mineral and exploration sector." 12.
"Since the Department of Energy and Mines (DEM) established the Mineral Resources Development Fund (MRDF) in 2018, it has given MANS $211,700. Each year MRDF gives out $1.5 million in grants for mineral exploration and research, and in the case of MANS, for mining promotion and PR." 12(b).
I can not agree with continued government subsidy and promotion of heavy polluting industry while public monies and attention to remediation and related environmental health issues remain underfunded and unresolved. The Agency should put stop to this mis-allocation of government funds by disapproving further investment in extractive polluting industries, such as gold mining.
Gold mining activity and Beaver Dam's associated haul road development does not comply with the Species at Risk Act with obvious potential negative effect on Mainland moose habitat. A dusty truck every passing by every two or three minutes for even a few years of satellite mine operation sounds "risky" to me, and unseemly unfair to other rural residents along the way who currently enjoy relatively quiet existence in surrounding woods and communities. 14.
Gold is not considered an essential element but is used mostly for jewellery and can be recycled indefinitely. Recycling gold is in keeping with the development of a circular economy, mining for more and more of it is not.  Gold, and other "precious" metal mining should now only occur in municipal landfills sites. $22.2 billion worth of gold and $1 billion worth of silver was thrown away worldwide in the form of electronic waste in 2016.  This is unacceptable waste of valuable world resources. The environmental damages cause by gold mining are now understood to be too costly to allow continued production of cheap disposable items. 15.
Regulations being created for the new Coastal Protection Act must also keep in mind cumulative impacts from historical mining and potential of multiple new mine sites if these proposed expansions of Touquoy mine operations are permitted. Particularly so if this industry is also to also to be permitted regulatory access to mine federal resources located offshore, as is proposed by the International Seabed Authority. 16.
I request the Agency increase environmental policy towards protecting the province from such non sustainable extractive development and inform exploration and extraction permit applicants to now instead procure desired resources from recycled sources such as city sewage and garbage. 17. 18. 19.
"Atlantic Gold’s last ESTMA report in 2018 shows it paid just $1.8 million in royalties to the province and $0 in taxes to any level of government." If you are unaware of Joan Baxter's investigative journalistic commentary on provincial gold mining developments, you may make good reference material of her detailed chronological reports in the Halifax Examiner. 20.
Government's recruitment of foreign investors at mining industry trade shows and fast track permit approval process to dig up Nova Scotia's top-soils for potentially shiny rocks hidden beneath is not acceptable business development to the understanding of Concerned Citizens of NS.

Thank you for your time and consideration.

Kindly,

Trudi Rhynold

<Personal information removed>

1. https://www.canada.ca/en/environment-climate-change/services/managing-pollution/publications/third-national-assessment-monitoring-data/executive-summary.html?fbclid=IwAR3AKyrG2e3vdQxItX-ccpqXAaLSoSZ0uNVh3q_fde7Dh2ycD3mqzj6RkiI
2. https://oag-ns.ca/sites/default/files/publications/July2020-2Full_0.pdf?fbclid=IwAR3CbRN1NR8bK1jLJgDfcl40j_OcQg2aKWRgTJqLYSi0uFXtXy2vljW52NQ
3 https://nslegislature.ca/sites/default/files/pdfs/committees/pa/pa_20200311.pdf?fbclid=IwAR3mG4HAQg4LLrPJgKpyIqdYRGo8UwS-Y63x_83G0nk1Afn2XYzghSqWAjI
4. https://journals.sagepub.com/doi/abs/10.3184/003685006783238344?fbclid=IwAR061Iv2Y0HRymh8bPSwj6bqxGJzsqPB2EsPbhB6pf5xIFKMfR9lXPl6d9M&
5. https://www.frontiersin.org/articles/10.3389/fmicb.2018.03348/full?fbclid=IwAR1aBhYGqBH2tJdvqXbRLRytfF62SjYgtOgeOWglg7dQR2g-2xO9QxYRG6I
6. https://www.researchgate.net/publication/317886266_Soil_Bioremediation_in_Heavy_Metal_Contaminated_Mining_Areas_A_MicrobiologicalBiotechnological_Point_of_View?fbclid=IwAR0XDud2DOQk0txeP1Xh4d20MHfAoRFv-JepGC0vrkLMutu0mbwXzLdp2AA
7. https://academic.oup.com/jimb/article/32/11-12/502/5992817?fbclid=IwAR25pU93vZfpcVApaYUtqrMqdiP_6Nqg-gdwl-HvCMvoHJ1sUSidIkSkulA
8. https://istina.msu.ru/media/publications/articles/c38/2f4/405773/IAEG_134-2006.pdf?fbclid=IwAR3_OrQkbaNuw9u3Ny4DVTVytt1kGJ-oZ7YoAjfHoIzn1MQ3qq3rigwDe8M
9. https://www.frontiersin.org/articles/10.3389/fenvs.2019.00066/full?fbclid=IwAR3W_CUhE0L02EreaQXyXHfMwC3zNCiZeKA8dXiYqzecSj3bfGbjNQm-krc
10. https://www.mdpi.com/2071-1050/12/17/7017?fbclid=IwAR02OvOnEVhIQHXDq4WXp0qVTfemxnaO5lpCD0oOLwH4obN6AaxY_nZfAKE
11. https://link.springer.com/article/10.1007/s41207-016-0008-3?fbclid=IwAR3KTjTYTsuNSPXuJY6vKP9x4tnzGkG4DfuZP6vyUA6PUcRF1P2CLYjm1gw
12. https://www.nrcan.gc.ca/.../pdf/Investment_Brief_e.pdf
12(b). https://www.halifaxexaminer.ca/province-house/mining-for-public-dollars/?fbclid=IwAR34FwH4jJ7bhht1GXZB-FpRnOG0_sSPnm9yOLl7dkyKpE9nfhc9De_C2xA
13. https://www.halifaxexaminer.ca/province-house/mining-for-public-dollars/?fbclid=IwAR3_OrQkbaNuw9u3Ny4DVTVytt1kGJ-oZ7YoAjfHoIzn1MQ3qq3rigwDe8M
14.  https://esajournals.onlinelibrary.wiley.com/doi/pdf/10.1890/ES14-00421.1?fbclid=IwAR29xBWZ3v1xIZGd4OxY0PAPX44V410gxJC1CGLKIgRuAClFr2bDUgMoM4k
15. https://www.kitco.com/news/2017-12-13/Over-20-Billion-Worth-Of-Gold-Thrown-Away-As-E-Waste-In-2016-Study.html?fbclid=IwAR0aXJhYYKv4wHOx_HUqdL9Ur0Vgu_NXxMKUj6ACYlZA91rPRNcIUKfIa-Y
16. https://www.isa.org.jm/about-isa?fbclid=IwAR3CbRN1NR8bK1jLJgDfcl40j_OcQg2aKWRgTJqLYSi0uFXtXy2vljW52NQ
17. https://www.smithsonianmag.com/smart-news/millions-dollars-worth-gold-and-silver-lurk-sewage-180953960/
18. http://www.enviroalternatives.com/landfill.html
19. https://www.sciencedirect.com/science/article/abs/pii/S0956053X15300052
20. https://www.halifaxexaminer.ca/featured/who-really-benefits-from-atlantic-golds-nova-scotia-operations/