Valentine Gold Project

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Attachment No Gold Mine!

  • Valentine Gold Project
  • Author: Nicole Corrado
  • Reference number: 101
  • Submitted: 2026-01-30 - 1:50 PM
  •   Please say NO to the Gold Project.  Gold mining involves the use of cyanide, which is deadly to all life.  Indigenous peoples live here.  Their homes would be destroyed, and they would be subject to the toxicity of mining.  The mine would also destroy the habitats of fish, birds, woodland caribou, pine martens, and plenty of other animals. During this climate emergency, we can not afford to destroy forests and wildlife habitat.     Gold mining is harmful to all life, and to the planet.  Forcing fish and birds to be exposed to the effluent, and cutting them up to test them for selenium and other pollutants is cruel and outdated.  Canada is phasing out toxicity testing on animals.  Please switch to animal free methods of testing effluent and other substances.  For wild fish and birds, please stop lethal sampling and switch to humane non lethal bio monitoring like is done in humans. https://www.change.org/p/stop-testing-sewer-water-on-laboratory-fish   Please do not build another gold mine.  We are in the midst of a climate crisis. This proposal, which would damage and destroy the homes of black bears, caribou, birds, fish, and many animals, is terrible.  And gold mines destroy all sorts of animals in laboratory testing of their effluents, and in lethal sampling of birds, fish, frogs, etc.  We do not need more gold mines. Please preserve the trees at this location.  Please do not build on an area that has a lot of trees, and do not build on a wetland either.  Please do not harm animals with this project. Please do not use animal testing for pollution monitoring.  It ...

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Attachment Hydrogéologie et Traitement de l’eau

  • Valentine Gold Project
  • Author: Public
  • Reference number: 100
  • Submitted: 2026-01-13 - 1:01 PM
  • je souligne l’importance d’assurer la protection des écosystèmes aquatiques et de la biodiversité, tant en amont qu’en aval du projet. Une gestion hydrogéologique rigoureuse, des systèmes de traitement des eaux adéquatement conçus et exploités et la révision du plan phase par phase pour ajustements, sont essentielles afin de prévenir le drainage minier acide et de maintenir durablement la qualité de l’eau.

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Attachment Please do not build this mine

  • Valentine Gold Project
  • Author: Nicole Corrado
  • Reference number: 91
  • Submitted: 2024-03-17 - 3:26 PM
  • ? ? ?Dear Valentine Gold,   Please say NO to the Marathon Valentine Gold Project.  Gold mining involves the use of cyanide, which is deadly to all life.  Indigenous peoples live here.  Their homes would be destroyed, and they would be subject to the toxicity of mining.  The mine would also destroy the habitats of fish, birds, woodland caribou, pine martens, and plenty of other animals. During this climate emergency, we can not afford to destroy forests and wildlife habitat.     Gold mining is harmful to all life, and to the planet.  Forcing fish and birds to be exposed to the effluent, and cutting them up to test them for selenium and other pollutants is cruel and outdated.  Canada is phasing out toxicity testing on animals.  Please switch to animal free methods of testing effluent and other substances.  For wild fish and birds, please stop lethal sampling and switch to humane non lethal bio monitoring like is done in humans. https://www.change.org/p/stop-testing-sewer-water-on-laboratory-fish   Please do not build another gold mine.  We are in the midst of a climate crisis. This proposal, which would damage and destroy the homes of black bears, caribou, birds, fish, and many animals, is terrible.  And gold mines destroy all sorts of animals in laboratory testing of their ...

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Attachment Please do not build this mine on wildlife habitat

  • Valentine Gold Project
  • Author: Animal Defence and Antivivisection Society of BC
  • Reference number: 90
  • Submitted: 2024-03-17 - 3:23 PM
  • ?Dear Valentine Gold,   Please say NO to the Marathon Valentine Gold Project.  Gold mining involves the use of cyanide, which is deadly to all life.  Indigenous peoples live here.  Their homes would be destroyed, and they would be subject to the toxicity of mining.  The mine would also destroy the habitats of fish, birds, woodland caribou, pine martens, and plenty of other animals. During this climate emergency, we can not afford to destroy forests and wildlife habitat.     Gold mining is harmful to all life, and to the planet.  Forcing fish and birds to be exposed to the effluent, and cutting them up to test them for selenium and other pollutants is cruel and outdated.  Canada is phasing out toxicity testing on animals.  Please switch to animal free methods of testing effluent and other substances.  For wild fish and birds, please stop lethal sampling and switch to humane non lethal bio monitoring like is done in humans. https://www.change.org/p/stop-testing-sewer-water-on-laboratory-fish   Please do not build another gold mine.  We are in the midst of a climate crisis. This proposal, which would damage and destroy the homes of black bears, caribou, birds, fish, and many animals, is terrible.  And gold mines destroy all sorts of animals in laboratory testing of their effluents, and in lethal sampling of birds, fish, frogs, etc.  We do not need more gold mines. Please preserve the trees at this ...

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Attachment Comment on Draft Environmental Assessment Report and Potential Conditions under CEAA 2012 - Valentine Gold Project

  • Valentine Gold Project
  • Author: MiningWatch Canada submitted by Jamie Kneen
  • Reference number: 71
  • Submitted: 2022-06-24 - 6:09 PM
  • Participation notice: Public Notice - Public Comments Invited on the draft Environmental Assessment Report and Potential Conditions
  • Please find attached the submission of MiningWatch Canada regarding the Draft Environmental Assessment Report and Potential conditions under the Canadian Environmental Assessment Act, 2012 for the Valentine Gold Project.
  • Attachment included
  • June 24, 2022 Valentine Gold Project Impact Assessment Agency of Canada 301-10 Barters Hill St. John’s, NL A1C 6M1 Telephone (709) 725-2725 valentine@iaac-aeic.gc.ca Re: Draft Environmental Assessment Report and Potential conditions under the Canadian Environmental Assessment Act, 2012 for the Valentine Gold Project in Newfoundland, IAAC registry number 80169 MiningWatch Canada has reviewed the above-referenced documents and is pleased to provide the following comments. They are focused on the issues we raised in the assessment process, principally regarding hydrogeological and geochemical concerns. There remain significant gaps that are not adequately addressed by the recommended conditions, and in a number of respects, there is not adequate evidence to support the Impact Assessment Agency of Canada’s conclusion in the Draft Environmental Assessment Report that “taking into account the implementation of mitigation measures, the Project is not likely to cause significant adverse environmental effects as defined in CEAA 2012.” We are also deeply concerned that the Draft Environmental Assessment Report states that “[t]he Agency acknowledges that the Project would result in adverse effects on caribou.”1 Those impacts are acknowledged to be potentially significant. How can this not impede the conclusion that the project is “not likely to cause significant adverse environmental effects”? MiningWatch Canada contracted Jim Kuipers, P.E., to prepare detailed comments on the Environmental Impact Statement for the Valentine Gold Project.2 The proponent’s responses to those comments vary in completeness and rigour, and in several areas do not provide sufficient assurance that ...

Attachment MFN Comments - Valentine EA Report and Conditions (80169)

  • Valentine Gold Project
  • Author: Administrator on behalf of Miawpukek First Nation
  • Reference number: 74
  • Submitted: 2022-06-24
  • Participation notice: Public Notice - Public Comments Invited on the draft Environmental Assessment Report and Potential Conditions
  • Please see attached document
  • Attachment included
  • Miawpukek First Nation Comments on the Valentine Gold DRAFT Environmental Assessment Report and Potential Conditions June 2022 2 Miawpukek First Nation – Comments on the Valentine Gold Environmental Assessment Report and Potential Conditions Table of Contents 1.0 Introduction .................................................................................................................................... 3 2.0 Comments on the Valentine Gold Project Environmental Assessment Report and Potential Conditions ................................................................................................................................................... 6 2.1 Community, Cultural Heritage, Land Use and Rights................................................................... 6 2.2 Aquatic Resources ..................................................................................................................... 10 2.3 Birds, Wildlife and Species at Risk ............................................................................................. 13 3.0 Concluding Remarks ...................................................................................................................... 15 References ................................................................................................................................................ 16 3 Miawpukek First Nation – Comments on the Valentine Gold Environmental Assessment Report and Potential Conditions 1.0 Introduction Marathon Gold Corporation (“Marathon”) is proposing to construct and operate the Valentine Gold Mine (“the Project”) in central Newfoundland (Figure 1). ...

Attachment Proposed Valentine Lake Gold Project EA comments

  • Valentine Gold Project
  • Author: Administrator on behalf of Canadian Parks and Wilderness Society
  • Reference number: 72
  • Submitted: 2022-06-24
  • Participation notice: Public Notice - Public Comments Invited on the draft Environmental Assessment Report and Potential Conditions
  • Please see attached document
  • Attachment included
  • 360 Topsail Rd, Suite 302 St. John’s, NL A1E 2B6 Web: www.cpawsnl.org June 23, 2022 To Whom It May Concern: Please accept this letter regarding the Draft Environmental Assessment Report, May 2022, on behalf of the Canadian Parks and Wilderness Society Newfoundland and Labrador Chapter (CPAWS NL) with an emphasis on caribou. According to the EA Report "The Proponent predicted that the Project would affect caribou through a change in habitat, movement and mortality risk. The Project is predicted to have an effect on both the Buchans and Grey River herds, and to a portion of the Grey River herd calving grounds.” Under Cumulative Effects, "The Agency is of the view that the Project will cause adverse cumulative effects on caribou. The Agency based this conclusion on its consideration of the project effects, the effects of other past, present and reasonably foreseeable projects or activities, the Proponent’s assessment, federal and provincial authority expert review, comments provided by Indigenous groups and the public, the proposed mitigation measures, and existing federal and provincial regulations..." However, “The Agency notes that re-design to the Project has been undertaken in consultation with Newfoundland and Labrador Department of Fisheries, Forestry and Agriculture Wildlife Division to reduce overlap with the migration path. (As well) the Proponent has committed to continuing to update its Caribou Protection and Environmental Effects Monitoring Plan in consultation with regulators, scientific experts, Indigenous groups and stakeholders. The Agency is of the view that the key mitigations described in the other valued component sections would reduce adverse ...
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Attachment Comments on the draft Impact Assessment Report and the proposed conditions

  • Valentine Gold Project
  • Author: Administrator on behalf of Qalipu First Nation
  • Reference number: 73
  • Submitted: 2022-06-24
  • Participation notice: Public Notice - Public Comments Invited on the draft Environmental Assessment Report and Potential Conditions
  • Please see attached document
  • Attachment included
  • ?.V Qalipu " FIRST NATION June 23, 2022 Valentine Gold Project Impact Assessment Agency of Canada 301-10 Barters Hill St. John's, Newfoundland and Labrador A1C 6M1 SUBJECT: Qalipu First Nation Comments on the draft Impact Assessment Report and the proposed conditions for the Valentine Gold Project The purpose of this letter is to provide comments on the draft Impact Assessment Report and the proposed conditions for the Valentine Gold Project. Qalipu First Nation (QFN) represents approximately 24,000 registered members in Newfoundland and abroad and is made up of 67 traditional Mi'kmaq communities across Newfoundland. As a band, we provide core programs and service to our members, including Environment and Natural Resources Management. QFN supports its members interests in protecting environmentally and culturally sensitive areas throughout our territory. Specific concerns include the effects this will have on flora and fauna in the area possibly including medicinal plants and food sources. While significant traditional use has not been well documented within the project area, the general area has been known to be of importance to Mi'kmaq people. Permanent habitat alteration will remove the ability for future traditional land use. Project operations should be conducted according to the highest environmental standards as outlined in the legislation of the Government of Canada, and the Government of Newfoundland and Labrador. The potential environmental effects as described by the proponent may have adverse effects on resources of cultural, historical, and traditional importance. Mi'kmaq people have no assumptions of superiority over other life forms. All of creation is sacred and ...

Attachment VALENTINE GOLD MINE IMPACT LOCATED ON NEWFOUNDLAND BEOTHUK FIRST NATION TRIBE'S INTERNATIONAL FEDERAL TREATY RIGHTS

  • Valentine Gold Project
  • Author: BEOTHUK FIRST NATION TRIBE submitted by CAROL Reynolds
  • Reference number: 59
  • Submitted: 2021-12-07 - 9:12 PM
  • PLEASE READ ATTACHMENT : BFNT VALENTINE GOLD PDF 
  • Attachment included
  • Beothuk First Nation Tribe(BFNT) Comments on the Valentine Gold Environmental Impact Statement March 29, 2019 Table of Contents 1.0 Introduction .................................................................................................................................................... 3 1.1 Project Background ...................................................................................................................................... 3 1.2 BEOTHUK First Nation ..................................................................................................................................... 9 1.2.1 Background. Culture, and History ............................................................................................................ 9 1.2.2 Historic Land Use and Cultural Values ................................................................................................... 14 1.2.3 BEOTHUK First Nation Rights ................................................................................................................. 15 2.0 Comments on the Valentine Project Environmental Impact Statement ...................................................... 16 2.1 Community, Cultural Heritage, Land Use and Rights................................................................................ 16 2.2 Water Resources ....................................................................................................................................... 32 2.3 Fish and Fish Habitat ................................................................................................................................. 16 2.4 Birds, Wildlife and Species at Risk ...
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Attachment Stop this project immediately

  • Valentine Gold Project
  • Author: Jordan Michael Lawrence
  • Reference number: 48
  • Submitted: 2021-03-04 - 8:21 AM
  • To whom it may concern,  I am a 30 year old Mi'kmaw man, I was born and raised in central NL. My life happened mostly outdoors, my memories are of encountering wild animals on my travels through the woods. In particular I remember coming across a single caribou about 10 years ago, it was something that profoundly impacted my sense of belonging on this island. Newfoundland has been forcefully colonized by our European ancestors, severely impacting the ability of Indigenous groups to represent themselves in any matter relating to their own livelihood. The Treaty of Utretch violently upended many peoples lives on this island and the effects are being felt today.  I am concerned that this project is going ahead regardless of what the scientific, wildlife, Indigenous and non-Indigenous advocates say. Job's will come and go, the older people who stand to benefit from this project are a select few, and do not represent the concerns of the majority of the population. This project is supposed to last 12 years, I will be 42 with young children, and they may never get to know what its like to have a caribou offer itself to you, whether as just a beautiful sight, or a meal.  I am concerned that the Valentine Lake project is simply a means for other junior or corporate mining interests to "partner up" in order to off set the cost of accessing these delicate sites. In fact, I find it very disheartening and outside the spirit of reconciliation with Indigenous peoples, that any resource extraction project on the island go ahead with out very specific and transparent agreements between concerned citizens, and our government, who are ultimately responsible for protecting our ...

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Attachment Valentine Gold Project - Public Comments

  • Valentine Gold Project
  • Author: Administrator on behalf of Kelly Young
  • Reference number: 50
  • Submitted: 2021-03-04
  • To Whom It May Concern:    As federally recognized members of the Qalipu Mi’kmaq First Nation we the Young sisters believe that we have a duty to provide comments and share our concerns relating to the ecosystem of the island of Newfoundland, with particular focus on protecting spiritually and culturally significant lands, as well as preventing disturbance to the extremely important wildlife which is located in the proposed Valentine Gold Mine Project area. We are Dayna M. Young and Kelly M. Young of Stephenville, NL. Our leisure time has often been spent in the wilderness of the island of Newfoundland with our parents, who are avid participants in hiking and documenting the unique ecosystem which the Province offers. We have spent time enjoying the various wildlife and harvesting resources, such as berries, from the land. We understand the importance of voicing concerns surrounding culturally and spiritually important aspects of their homeland.  Attached are our comments on the Proposed Valentine Gold Project, and its potential impacts to the way of life for the Indigenous peoples in Ktaqmkuk.
  • Attachment included
  • Valentine Gold Project: Comments on the draft Environmental Impact Statement (EIS) Guidelines The Young Sisters To Whom It May Concern: March 04, 2021 Valentine Gold Project Canadian Environmental Assessment Agency 301-10 Barters Hill St. John's, Newfoundland and Labrador A1C 6M1 Telephone: 709-725-2725 Email: CEAA.Valentine.ACEE@canada.ca Kelly M. Young Dayna M. Young St. John’s, NL Brampton, ON Email: As federally recognized members of the Qalipu Mi’kmaq First Nation we the Young sisters believe that we have a duty to provide comments and share our concerns relating to the ecosystem of the island of Newfoundland, with particular focus on protecting spiritually and culturally significant lands, as well as preventing disturbance to the extremely important wildlife which is located in the proposed Valentine Gold Mine Project area. We are Dayna M. Young and Kelly M. Young of Stephenville, NL. Our leisure time has often been spent in the wilderness of the island of Newfoundland with our parents, who are avid participants in hiking and documenting the unique ecosystem which the Province offers. We have spent time enjoying the various wildlife and harvesting resources, such as berries, from the land. We understand the importance of voicing concerns surrounding culturally and spiritually important aspects of their homeland. Kelly is currently a graduate student at Memorial University of Newfoundland in St. John’s, completing the Master of Environmental Science program. By obtaining a B.Sc. through Memorial University with study focuses on Biology and Geography, Kelly has studied the complex relationship with which the biological community ...

Attachment No too the Valentine gold project

  • Valentine Gold Project
  • Author: Charissa Reeves
  • Reference number: 47
  • Submitted: 2021-03-03 - 4:29 PM
  • The Newfoundland wildlife Division has said in no uncertain terms that this project is a threat to the caribou herds in the area. Canadian caribou herds, including those in Newfoundland and Labrador are in danger of extinction. It has been well documented that mining development in caribou habitat threatens these herds and causes their numbers to dwindle. This project should absolutely not go ahead.      

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Attachment NRCan Submission for Valentine Gold - EIS Technical Review (Jan 2021).docx

  • Valentine Gold Project
  • Author: Administrator on behalf of Natural Resources Canada
  • Reference number: 40
  • Submitted: 2021-01-19
  • Please see the attached submission.
  • Attachment included
  • December 9, 2020 CIAR File No.: 80169 Brent Keeping Project Manager, Atlantic Region Impact Assessment Agency of Canada brent.keeping@canada.ca Subject: Natural Resources Canada’s Submission for Technical Review of the Environmental Impact Statement for the Valentine Gold Project On November 3rd, the Impact Assessment Agency of Canada (the Agency) requested that Natural Resources Canada (NRCan) conduct a technical review of Marathon Gold Corporation’s (the Proponent) Environmental Impact Statement (EIS) for the proposed Valentine Gold Project (the Project) near Valentine Lake, Newfoundland and Labrador. NRCan is participating in the environmental assessment process pursuant to Section 20 of the Canadian Environmental Assessment Act, 2012 as a Department in possession of specialist or expert information or knowledge related to the Project. NRCan has conducted a technical review to assess the sufficiency and technical merit of the EIS and supporting documents (CIAR #17) based on the Department’s expertise in hydrogeology, acid rock drainage and metal leaching, and in the context of the Department’s regulatory role under the Explosives Act. Details of NRCan’s review can be found in the attached appendix below. If you have any questions, please contact me via e-mail at walker.smith@canada.ca or by phone at (613) 447-2892. Thank you, Walker Smith Environmental Assessment Officer Office of the Chief Scientist cc: John Clarke – Director, Environmental Assessment <original signed ...

Attachment MFN EIS Comments - Valentine Gold

  • Valentine Gold Project
  • Author: Administrator on behalf of Miawpukek First Nation
  • Reference number: 35
  • Submitted: 2021-01-08
  • Please see the attached submission.
  • Attachment included
  • Miawpukek First Nation Comments on the Valentine Gold Environmental Impact Statement December 23, 2020 2 Miawpukek First Nation – Comments on the Valentine Gold Environmental Impact Statement Table of Contents 1.0 Introduction .................................................................................................................................... 3 1.1 Project Background ........................................................................................................................... 3 1.2 Miawpukek First Nation ........................................................................................................................ 6 1.2.1 Background. Culture, and History ........................................................................................... 6 1.2.2 Historic Land Use and Cultural Values ..................................................................................... 7 1.2.3 Miawpukek First Nation Rights ...................................................................................................... 8 2.0 Comments on the Valentine Project Environmental Impact Statement ......................................... 9 2.1 Community, Cultural Heritage, Land Use and Rights................................................................... 9 2.2 Water Resources ....................................................................................................................... 12 2.3 Fish and Fish Habitat ................................................................................................................. 18 2.4 Birds, Wildlife and Species at Risk ...

Attachment Submission

  • Valentine Gold Project
  • Author: Administrator on behalf of Brian McLaren and Richard Huang
  • Reference number: 32
  • Submitted: 2020-12-30
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Hello,  Please find attached a submission prepared by Brian McLaren and Richard Huang. I have also forwarded it to Brent Keeping in St. John's. Please let me know if you have any questions and advise whether I should submit through additional means.    Sincerely,    Glenn Wheeler <personal information removed>
  • Attachment included
  • Comments on the Marathon Gold Valentine Lake Project’s Environmental Impact Statement: Relating to Fish and Wildlife and Mitigating the Effects on Area Caribou December 30, 2020 Brian McLaren1 and Richard Huang2 Preamble Marathon Gold has provided an Environmental Impact Statement (EIS) on its proposed Valentine Gold Project in west-central Newfoundland that became available for public review and comment in November 2020. This public review is taking place as part of the consultations mandated by the Canadian Environmental Assessment Act and the Newfoundland and Labrador Environmental Protection Act. Comments made during public review are intended to assist the Ministers of government in decision-making on how approval for the undertaking might take place. The Valentine Gold Project starts with a construction phase of 18-24 months, followed by an estimated mine operation life of over 12 years, then a two-year site rehabilitation and closure period forecast for 2035-36, followed by a five-year commitment to post-closure monitoring. Comments related to the disturbance to caribou that will occur throughout the construction, operation and closure periods of the Valentine Gold Project, over at least 15 years should it move forward as described, are the justifiable focus of this brief report on the fish and wildlife impacts described in the EIS. The report draws on caribou data obtained from the Newfoundland and Labrador Wildlife Division. The report illustrates a high level of concern that the EIS is underplaying the serious potential effect of the project particularly on the Buchans Plateau caribou herd, and to a lesser extent on the Grey River and La Poile ...

Attachment Submission on Valentine Gold - Technical report highlighting concerns on scope, scale, and completeness of baseline information collection

  • Valentine Gold Project
  • Author: Alana Westwood
  • Reference number: 28
  • Submitted: 2020-12-23 - 9:06 AM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please see the attached file for the complete report. The covering letter is reproduced below. December 23, 2020 Enclosed past this covering letter are recommendations for consideration by the Impact Assessment Agency of Canada, the Marathon Gold Corporation, and federal authories in your ongoing assessment of the Valentine Gold Project. These recommendations were prepared by graduate students 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 (including Master’s and PhDs), and cumulative decades 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 Valentine Gold EIS and raise concerns with the quality and scope of data collection and the feasibility and adequacy of proposed mitigation measures. Summary of recommendations Air quality The baseline test for air quality was inadequately repeated (N = 4) to construct an accurate representation of conditions, particularly compared to a similar mine which constructed a baseline over a year. The proponent should re-do the testing over several months to adequately record baseline ...
  • Attachment included
  • FACULTY OF MANAGEMENT | School for Resource and Environmental Studies Kenneth C. Rowe Management Building, Suite 5010 | 6100 University Avenue | PO Box 15000 | Halifax NS B3H 4R2 Canada 902.494.3632 | FAX: 902.494.3728 | sres@dal.ca | dal.ca/sres DAL.CA Valentine Gold Project Impact Assessment Agency of Canada 301-10 Barters Hill St. John's, Newfoundland and Labrador A1C 6M1 CEAA.Valentine.ACEE@canada.ca December 23, 2020 To whom it may concern, Enclosed past this covering letter are recommendations for consideration by the Impact Assessment Agency of Canada, the Marathon Gold Corporation, and federal authories in your ongoing assessment of the Valentine Gold Project. These recommendations were prepared by graduate students 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 (including Master’s and PhDs), and cumulative decades 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 Valentine Gold EIS and raise concerns with the quality and scope of data collection and the feasibility and adequacy of proposed mitigation measures. Summary of recommendations Air quality • The baseline test for air quality was inadequately repeated (N = 4) to construct an accurate representation of conditions, particularly compared to a similar mine ...

Attachment EIS Submission Marathon Gold Project

  • Valentine Gold Project
  • Author: Administrator on behalf of Snowshoe Lake Hunting and Fishing
  • Reference number: 33
  • Submitted: 2020-12-23
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Hi: Attached you will find comments and concerns from Snowshoe Lake Hunting and Fishing, whom is Outfitting business located in the area near the Valentine Lake Gold Project.  If any questions, please feel free to contact me anytime. Regards, SNOWSHOE LAKE HUNTING AND FISHING   Ron Hicks 41 Bouzane Street Grand Falls-Windsor, NL  A2A 2W7 1-709-489-3017
  • Attachment included
  • December 23, 2020 Government of Newfoundland and Labrador Environment Assessment Division Dept. of Environment, Climate change and municipalities West Block, Confederation Building P.O. Box 8700 St. John’s, NL A1B 4J6 EAprojectcomments@gov.nl.ca Iaac.valentine.aeic@canada.ca RE: Marathon Gold Valentine Lake EIS Submission concerns To Whom It May Concern: February 2021 Snowshoe Lake Hunting and Fishing will be celebrating 28 years of successful business within the Outfitting Industry; an industry that has a long history in Newfoundland dating back to the 1800’s and is the oldest form of tourism in Newfoundland and Labrador. Our primary activities is providing quality hunting and angling experiences to clientele worldwide. Within the tourism industry, the outfitting industry has the greatest yield and year over year inject brand new non recycled monies into the Newfoundland and Labrador economy, especially in rural parts of our great province. To continue to enjoy this it is very important to recognize key elements and characteristics on the landscape that must be protected and enhanced to ensure we have a product that is world class, otherwise we quickly lose our competitive edge in luring tourist to this area of the province. Operations Snowshoe Lake Hunting and Fishing’s lodge is located at Snowshoe Pond 63 km’s southwest of the town of Millertown, yet in viewing topographic mapping the Marathon Gold project is estimated to be 20 to 21 km’s from our lodge as the crow flies. Our business model is to spread hunting opportunities throughout a large portion of the moose management area as oppose to a small radius around ...

Attachment Comments on Valentine Gold Project - IAAC registry no. 80169, NLDECCM registration no. 2015

  • Valentine Gold Project
  • Author: Administrator on behalf of MiningWatch Canada
  • Reference number: 31
  • Submitted: 2020-12-23
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Please see attachment.
  • Attachment included
  • December 23, 2020 Valentine Gold Project Canadian Environmental Assessment Agency 301-10 Barters Hill St. John’s, NL A1C 6M1 Telephone (709) 725-2725 CEAA.Valentine.ACEE@canada.ca Eric Watton, M.Sc. Project EA Committee Chair Environmental Assessment Division Department of Environment, Climate Change and Municipalities Fourth Floor, West Block, Confederation Building P.O. Box 8700, St. John’s, NL A1B 4J6 EAProjectComments@gov.nl.ca Re: Environmental Impact Statement (EIS) for the Valentine Gold Project in Newfoundland – IAAC registry number 80169, NLDECCM registration number 2015 About MiningWatch Canada: MiningWatch Canada is a non-governmental organization (NGO) created in 1999 as a co-ordinated public interest response to the threats to public health, water and air quality, fish and wildlife habitat, and community interests posed by irresponsible mineral policies and practices in Canada and around the world. We are supported by twenty-seven Canadian environmental, social justice, Indigenous, and labour organisations, collectively representing tens of thousands of members across Canada. Among other areas of work, we provide technical and strategic support to Indigenous and non-Indigenous communities, organisations, and governments across the country, and we have intervened directly in a large number of mining-related environmental impact assessments as well as working with community groups and experts on many others. MiningWatch Canada contracted Jim Kuipers, P.E., to prepare the attached detailed comments on the Environmental Impact Statement for the Valentine Gold Project. Below is a summary of those comments. Summary of Technical ...
  • Attachment included
  • Valentine Gold Project EIS Comments J. Kuipers P.E., on behalf of MiningWatch Canada 22 December 2020 Introduction The following review comments have been developed on behalf of MiningWatch Canada for the proposed Valentine Gold Project Environmental Impact Statement (EIS), IAAC registry number 80169, NLDECCM registration number 2015. These comments are based on my professional training and experience. I have an extensive background with more than 37 years involvement in mining metals and minerals including in the full-life cycle of exploration, project development, project permitting, construction, operations, reclamation, and closure. I graduated in 1983 with a B.S. in Mineral Processing from Montana School of Mines. In addition to growing up in a mining family and gaining practical experience prior to entering university, I have worked as a senior engineer, chief metallurgist, mill superintendent, mine manager, project manager, and consulting engineer. Since 1996, I have been the principal consulting engineer with Kuipers & Associates. My work during that time has focused on providing technical expertise to public interest groups, Tribes and First Nations, and governments concerning mining and environmental concerns. The primary areas of expertise I have provided have included site characterization, water quality predictions, mine planning and mitigations, tailing storage facilities, mine reclamation and closure, site investigations and remediation, water treatment, financial assurance, and economic evaluations. 2.1 CHANGES TO THE PROJECT SINCE ORIGINALLY PROPOSED According to Table 2.1 Key Refinements, Heap Leach Process and Infrastructure, Revised Project Design, With removal ...

Attachment Valentine Gold Mine

  • Valentine Gold Project
  • Author: Barry Fordham
  • Reference number: 26
  • Submitted: 2020-12-20 - 12:47 PM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • I am very concerned about the habitat and the Wildlife of the area, especially the Woodland Caribou. I understand that an EIS has been completed and submitted. While the Company has studied and implemented mitigation measures, the NL Wildlife Division don't seem very accepting of this project as it pertains to the Woodland Caribou. I think that this needs to be seriously studied again so that it is confirmed that the project has a low impact and a small carbon footprint.

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Attachment Please stop the gold rush

  • Valentine Gold Project
  • Author: Michael Plummer
  • Reference number: 25
  • Submitted: 2020-12-18 - 7:08 AM
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • I have reviewed a great deal of data about this project. I have also listened to the assessments of professionals who are former mining engineers who have all said this is not a good project. The potential impacts caused by the mass of infrastructure to bring this mine online as well as the mining itself WILL IMPACT the caribou herds who rely on this region for their survival. I implore this government to listen to the woodland caribou experts! This project is temporary and will not bring long term sustainable economic benefit to the local community. Most of the profits will go to the owners and shareholders of the mine. Please do not approve permitting for this mine. Our Caribou, our water, and this ecosystem is worth more than gold! 

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Attachment Valentine Gold EIS Technical Review Request

  • Valentine Gold Project
  • Author: Administrator on behalf of Department of Fisheries, Forestry and Agriculture
  • Reference number: 36
  • Submitted: 2020-12-18
  • Please see the attached submission.
  • Attachment included
  • Tables for the EAC of the Valentine Gold Project EIS Review – Registration 2015 Table 1. Agency Comments (Evaluation) on the EIS EIS Guideline within your mandate Does the EIS answer the specific guideline requirement? Yes or No. Is this section deficient, contain errors or require further mitigation? If no, explain how the guideline has NOT been met by the EIS.? What else is needed? 3.0 Scope of project, factors to be considered and scope of factors 3.1 Scope of Project: Air emission sources including dust lift-off. Noise sources, expected noise levels and noise monitoring locations. Sources and frequency of vibrations including seismic loading (Victoria Dam and wildlife). No. While the EIS mentions dust, noise & vibrations it does not adequately address them Yes (Requires Further Mitigation) The EIS does not address the impact of dust on caribou & its habitat (see comments in Annex A). The EIS does not address noise & stress response in caribou (see comments in Annex A). The EIS mentions vibrations, such as in Sections 11.5.1.1 (page 11.53) 12.5.1.1. (pages 12.58- .59), but it does not describe how the magnitude will be measured or mitigations planned. 4.2.1.2 Woodland Caribou (Habitat, Migratory Behaviour and Cumulative Effects) No Yes (Deficient) Annex A provides specific comments related to Woodland Caribou throughout the EIS. The Baseline Caribou Study (Appendix 2 of the EIS) does not adequately: Represent the extent of use of the project area by caribou and relate it to the degree of risk posed by project components Integrate common findings between the ...
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Attachment CPAWS NL Review of Marathon Gold Valentine Lake

  • Valentine Gold Project
  • Author: Administrator on behalf of Canadian Parks and Wilderness Society Newfoundland and Labrador
  • Reference number: 30
  • Submitted: 2020-12-18
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Good Day Please find attached 2 documents in regards to the proposed Valentine Lake Gold Mine. As an environmental non for profit charitable organization in the province, we have concerns in regard to the impact this project may have on wildlife, especially caribou.  In May 2019, the NL provincial wildlife division recommended against the mine because of concerns that the mine development would negatively impact several caribou herds that use this area as a migration corridor. CPAWS NL  has sought experts (  Dr. B. Kopach, MSES Inc) to review the caribou assessment ( attached), which points out several aspects that are inadequate. We have also observed other environmental concerns and have identified them in an additional document ( attached) and seek clarification and additional information to be publically provided.   Therefore, we recommend that this mine development not be approved unless the plan for evaluating and mitigating the possible impacts on caribou, have addressed the concerns raised by these reviews and unless the NL wildlife division is satisfied that the predicted impacts on caribou have been effectively predicted and the mine proposes an adequate plan for mitigating predicted impacts on caribou.   Regards Suzanne Dooley _____________________________________   Suzanne ...
  • Attachment included
  • MITIGATION MEASURES/PRACTICES OBSERVATIONS • The documents uses a widespread use of vague terminology when describing the proposed mitigation measures. There is no quantification of how effective the measures will be, and there is no contingency plan in case a proposed mitigation measure fails to deliver the expected outcome. The comments below focus on the Environmental Impact Statement section reporting on the proposed mitigation measures for Caribou (Section 7.8.2.2, Table 7.7, pages 7.50, 7.51, and 7.52.). However, the issue highlighted above is recurrent throughout the EIS. • The proponent indicates a total of 30 mitigation measures to reduce negative impacts on Caribou. Of these, approximately 1/3 contain vague terms such as “to the extent practicable”, “where feasible”, “limited to that which is necessary”, “proper handling and storage”. • For example, when the proponent states “Vehicles and heavy equipment will be maintained in good working order and will be equipped with appropriate mufflers to reduce noise.”, many questions remain unanswered: ▪ What is the definition of “good working order” and what standards are being followed? ▪ What is an “appropriate muffler? ▪ What is the reduction in noise emission expected from the implementation of the measure? ▪ How will the proponent evaluate whether or not the measure is effective? ▪ What will be done in case maintaining a “good working order” and using “appropriate mufflers” are found to be ineffective at mitigating noise? • Some of the measures are deferred, pointing to the development of management plans (e.g., “Project facilities and infrastructure will be designed to limit noise ...
  • Attachment included
  • 1 Memo To: Suzanne Dooley, CPAWS NL Simone Cominelli, CPAWS NL File no: 2058 From: Brian Kopach ( ) cc: Abbie Stewart Tel: Date: December 18, 2020 Subject: Review of the Woodland Caribou Assessment in the Valentine Gold Mine Environmental Impact Statement Executive Summary Key findings of the caribou assessment review include: • Quantitative analysis of caribou habitat preferences, connectivity, and fragmentation are currently missing from the assessment. This information would further our understanding of predicted impacts of the proposed project, such as potentially severing the migration corridor for the Buchans caribou herd. • Impacts of indirect habitat loss are underestimated because the size of the LAA is defined using a buffer around the development that is smaller than observed response distances of caribou to industrial developments in the region and across Canada. • There is a lack of detail provided on the follow-up and monitoring plans. No monitoring targets or triggers for management action are identified and there is a lack of peer-reviewed literature or monitoring reports from other similar projects used to demonstrate proposed mitigation effectiveness. • The amount of landscape disturbance is not quantified in the cumulative effects assessment making it difficult to know how close regional caribou herd ranges are to the 65% undisturbed habitat threshold identified in the woodland caribou recovery strategy (Environment Canada, 2012). <email address removed> <personal information removed> 2 1.0 Introduction Management and Solutions in Environmental Science ...
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Attachment NLOA Valentine Lake EIS Submission

  • Valentine Gold Project
  • Author: Administrator on behalf of Newfoundland and Labrador Outfitters Association
  • Reference number: 29
  • Submitted: 2020-12-18
  • Participation notice: Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
  • Good Morning Everyone,   Please find attached the NLOA’s submission for the Marathon Gold Valentine Lake EIS.   The NLOA felt a great deal of support for our industry and outfitters from Marathon Gold up to a week ago. That has since changed a little when we found out that the work they were doing with the one Outfitter seriously impacted to date has almost ceased. They began work with Notch Mountain Outfitters a few years back because they knew right from the start, his Valentine Lake operation would have to close as it was less than 4kms from the project site. The outfitter lost that portion of his business, has lost a lot of money since, and will lose hundreds of thousands of dollars over the life of the mining project. Marathon Gold were working closely with him in terms of a compensation package but recently hadn’t responded to any of his attempts to contact them for a period of more 2 months. They only recently responded when he threatened legal action and got his law firm involved but only to say they were sorry for the delay and were working on it and would be in touch.   Based on this recent information, one thing missing from the EIS that we would like to see in there is an Outfitter Environmental Effects Monitoring Plan to protect our outfitters and our industry. I’ve detailed this in our submission but if any of you would like to talk further about this, I am certainly open to discussing and available for a call up until Tuesday Dec 22/20.   Eric and Brent, can each of you please reply to confirm receipt. It would be very much appreciated.   Thank you and ...
  • Attachment included
  • December 18, 2020 Cory Foster, Executive Director Newfoundland and Labrador Outfitters Association Good Morning, As you are aware, the Newfoundland and Labrador Outfitters Association (NLOA) is the provincial non-profit outfitting industry association. We currently represent 118 outfitting businesses located all throughout NL and advocate on their behalf to ensure that our industry continues to move forward in a positive successful manner. I am sure by now that you have received submissions from some outfitters who are deeply concerned with the proposed Valentine Lake Gold Mine. Most of our outfitters in Central are remotely located and offer some of the best wilderness hunting in Newfoundland because of their location. They offer premium products/services at premium prices and can do so because of their remoteness and the animals available to them in these remote areas. These outfitters are located from less then 4kms to 50+kms away from the project site, they hunt and fish the areas near the site (some of them have been doing so for more than 30 years), and they will feel significant effects from this project. Thus, there is certainly fear that this project will negatively change what some have spent decades to build. The NLOA has had numerous meetings over the past few months with Marathon Gold, Provincial Officials from Wildlife and Tourism, Federal Political Officials, stakeholders nationwide, as well as with our own members who echo concerns. Based on our review of the EIS and findings from our meetings, we have identified 6 key areas of concern with the project. These areas are Woodland Caribou, other wildlife including moose and Atlantic Salmon, acoustic disturbance, the ...
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