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

Reference Number
Date Submitted
2020-12-23 9:06:00 AM

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 conditions.
  • Baseline information for PM2.5, O3, NO, NOXa should be collected nearer to the site rather than relying on an air quality station 120 km away.
  • Similar CEAA 2012-approved projects have air quality and emissions plans, and the proponent for Valentine Gold should be required to develop an air quality and emissions plan one for this project.


Community health

  • Valentine Gold’s EIS includes only one paragraph about anticipated cumulative health impacts, most of which implies that mitigation responsibility largely relies on other projects (e.g. Buchans Resource Limited Project). Given a long operating life and profound anticipated demographic changes in the project area, this paragraph is not sufficient for informed decision-making, and a specific Health Impact Assessment should be conducted and included.

Gender equity and diversity

  • Despite significant reported adverse impacts from accommodation camps on women and Indigenous communities, like the one planned for the project and which the proponent admits will be mostly composted of non-Indigneous men, this context is not discussed or approached from a Gender-Based Analysis Plus lens. The Project should implement a GBA+ framework including GBA+ training for all employees, regardless of level.
  • The proponent should detail what measures will be specifically taken to protect LGBTQ2S+ persons from adverse outcomes, both within local communities and among the project workforce.

Species at risk and wildlife

  • Despite there being nine identified species at risk expected to have direct impacts from the project, species at risk are not categorized as a unique VC. Impacts of species at risk should be separated into a standalone section to improve the ability to evaluate provided information.
  • Using the same local assessment area (LAA) and regional assessment area (RAA) for each species is not biologically or ecologically appropriate to capture predicted impacts. Impacts on species should be re-estimated using appropriate LAA and RAA sizes for those organisms.
  • A subpopulation of an endemic species at risk, the Newfoundland Marten, has critical habitat in the project area. Habitat offsets should be established and permanently protected.
  • Despite increasing risks to their populations, including white-nose syndrome, northern long-eared bats and little brown bats were not adequately surveyed. The proponent should conduct more rigorous bat surveys to better understand their distribution and movements to allow for accurate impact prediction.
  • The mining site occurs directly within a woodland caribou migration route and places this herd at increased risk of predation and disturbance. The proposed buffer distance (500 m) is well below known thresholds for caribou avoidance of industrial operations, and predicted habitat loss is severely underestimated. Given the at-risk status of this species in Newfoundland, the proponent should increase buffer distances and pause operations yearly during peak migration seasons.
  • The proponent should explain why the Pot Hill Caribou herd was not included in the analysis.
  • There remain significant risks to habitat of avifauna at risk. To mitigate these, the proponent should ensure a minimum 120m buffer distance for construction and operation from all freshwater bodies, monitor the site and nearby area for avifauna, and minimize clear-cut amounts
  • The impacts of noise on avifauna were not adequately considered. The proponent should conduct blasting only during daytime hours, install noise barriers, and use centralized compressors to prevent unregulated noise from machinery

Surface water quality

  • Proposed tailings-related mitigations are not adequate compared to the risk of failure consequences which are described by the proponent as likely to have “very high” environmental impacts. Given the low acid buffering potential of local and regional waters, a comprehensive grading plan is needed designed to contain, monitor and treat water that has contacted tailings, waste rock piles, and low- and high-grade ore stockpiles, and prevent contaminents from entering proximal water bodies.
  • Due to an already chemically weakened aquatic system, effluent discharge from the project could severely damage the surrounding aquatic environment. The proponent should continuously monitor effluent interactions with the receiving environment beyond mine closure.
  • The project considers itself spatially isolated from other mining projects in the region, leading to to underestimation of cumulative effects. However, there are larger watershed connections between these projects. The proponent should increase the LAA to reassess its hydrologic connectivity and interactions with other projects for the purposes of cumulative effects assessment.
  • The proponent should more specifically define “high runoff events”.

Vegetation, wetlands, terrain, and soil

  • This section includes a large number of subcomponents and is difficult to evaluate as a group. A revised EIS should be consistent with other CEAA 2012-approved projects and split this section into four separate sections to allow for careful evaluation of methods.
  • The initial ecological land classification study did not include specific details about forest composition or successional stages, which are crucial to understand risks to important habitats and features like old-growth forests as well as landscape fragmentation risks. The proponent should re-do the ecological land classification study and report on square kilometres of each forest type and age likely to be impacted.
  • Insufficient details given about vegetation sampling regime (e.g. timing, approach to random stratification) to evaluate if the sampling approach met a quality standard needed to detect species at risk/species of conservation concern. More details about vegetation sampling scheme should be provided, and the Proponent should establish permanent sample plots to monitor vegetation rehabilitation over a realistic timeline for re-establishment of alpine/boreal vegetation on mineral soils (~100 years).
  • Proposed site rehabilitation to restore native vegetation community includes seeding with native species. However, due to the difficulties of revegetation in boreal and alpine habitats, particularly on mineral soils, this is likely to be inadequate to prevent colonization of invasive species and to ensure replacement of original ecosystems. A more comprehensive and adaptive approach to vegetation rehabilitation should be undertaken by the Proponent, including long-term trials and revegetation studies.

The remainder of the document is a compilation of 4 brief reports on differing elements of the EIS, each with an executive summary, analysis, recommendations, and supporting citations. The full document may be cited as:

Westwood, A., Bailie, J., Cameron, J., Carter, L., Ceci, S., Clarke, M., Collison, B., Deblois, K., Dvorski, H., Gardner, D., Haddad, C,. Kavanagh, D., Lopez, M., Reid, P. 2020. Submission on concerns and recommendations related to the proposed Valentine Gold project in Newfoundland and Labrador. Prepared for the Impact Assessment Agency of Canada. 65pp.

All coauthors consent to the public release of our work. Dr. A. Westwood, as the principal investigator and course instructor, certifies the technical soundness of the analysis and recommendations herein.

Thank you for your consideration, and we hope our recommendations can support a project and IA process which is more technically sound, just, and supports long-term environmental and economic prosperity in Newfoundland and Labrador.


Dr. Alana Westwood (on behalf of the coauthors)

Assistant Professor, School for Resource and Environmental Studies

Faculty of Management, Dalhousie University, K'jipuktuk (Halifax)

Direct inquiries to (


Submitted by
Alana Westwood
Public Notice
Public Notice - Public Comments Invited on a Summary of the Environmental Impact Statement
Comment Tags
Air Quality Species at Risk Soil Surface Water Quality Human Health and Well-Being Community / Regional Services Terrestrial Plants Wetlands Vulnerable Population Groups (Gender-based Analysis Plus (GBA+))
  • Westwood et al. 2020 Valentine Gold Submission.pdf (923920 KB)
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