I support a full and thorough federal environmental assessment for this mega gold mine project. The scale of this development requires careful review to protect our environment, wildlife, and communities.

To whom it may concern, 

    I write to you as a community member, angler, paddler, birder and ecologist. As many other community members in Sherbrooke, I have a deep connection with the watershed and forest in the Sherbrooke area. Not only do I spend a great deal of time outdoors observing and studying native flora and fauna, but I also have a background managing fisheries, and woodlands here in Nova Scotia. 

    The importance of the areas surrounding the proposed developments cannot be overstated. This region is one of Nova Scotia's most ecologically valuable landscapes and provides habitat for many federally protected species, a wide biodiversity, forests and wetlands that provide critical ecosystem services like carbon sequestration, air and water filtration. Rivers and lakes that provide a clean water supply, fish and other animal habitat, and nutrient cycling. This importance has been identified by Fisheries and Oceans Canada as the Saint Marys River has recently been declared as the first candidate for designation as an Ecologically Significant Area under the Fisheries Act. These benefits have been greatly aided by many restoration projects in the surrounding areas. For decades, Indigenous communities, conservation organizations, volunteers, and government agencies have invested millions of dollars and countless volunteer hours restoring the St. Mary's River and its surrounding watershed.

    These conservation gains could be placed at risk by the proposed reopening and expansion of the former Atlantic Gold mining operations, now owned and operated by St Barbara Limited of Australia. The proposal includes the redevelopment of the 15-Mile Mine (formerly Fifteen Mile Stream), Old Austin Mine (formerly Beaver Dam), and Old Mitchell Mine (formerly Cochrane Hill). Unlike the previous proposal, this new project would function as a much larger regional mining and processing hub, combining multiple mine sites into a single operation. Given its expanded scope, the project has the potential to result in significant adverse effects, including risks to water quality in the respective watersheds, impact to fish and fish habitat, disturbance, displacement and potential death of endangered and federally protected species at risk.

    Clean, fresh water is recognized as a fundamental human right because it is essential to life. The same is true for the fish, wildlife, and ecosystems that depend on healthy rivers, streams, wetlands, and lakes surrounding the proposed development sites. This project poses potential significant risks to watercourses during mine construction, operation, and closure. During the initial construction phase, clearcutting and grubbing will remove vegetation that helps stabilize soils. Without adequate erosion and sediment control measures, rainfall can carry sediment into nearby watercourses, reducing water clarity, limiting sunlight penetration, degrading water quality, and covering fish spawning habitat. During mine operations, ore and overburden stockpiles also present potential environmental risks. Before ore is transported for processing, both ore and overburden may be exposed to rainfall. This can result in leaching of heavy metals and acid mine drainage. Following the closure, the open pits are expected to fill with water, creating pit lakes. During this process, we will see a significant amount of water “caught” in the pits which will reduce the direct amount of water in the surrounding watersheds. This is a significant concern for the Saint Marys River with recent record low water levels in the river.

    The St. Mary's River is one of the last and most important remaining wild Atlantic salmon populations in mainland Nova Scotia. Atlantic salmon populations throughout Nova Scotia have declined significantly over the past several decades, making the protection of their remaining habitat increasingly important. Being anadromous, Atlantic salmon spend part of their life at sea feeding and growing, before returning into our rivers to spawn. This process is critical for nutrient cycling in the rivers. Atlantic salmon are also considered an indicator species because their survival requires clean, cold, oxygen rich water and healthy spawning habitat. When rivers are polluted, Atlantic salmon are the of the first species to feel the impacts. With increased truck traffic, blasting, crushing, and open-pit excavation occurring in close proximity to the river, there is the potential for airborne dust and other fine particulate matter to be transported by wind and deposited into the St. Marys River and surrounding watercourses. Dust deposited in the surrounding land can also be later carried into the river through rainfall events. If sufficient quantities of sediment enter the river, water quality can be degraded through increased turbidity, reducing the amount of sunlight reaching aquatic vegetation that juvenile salmon use as cover against predation. Fine sediment can also settle into the gravel beds where Atlantic salmon lay their eggs. This sediment fills the spaces between the gravel, restricting the flow of oxygen rich water that Atlantic salmon require to survive. Suspended sediment can also irritate or clog salmon gills during periods of elevated concentrations, increasing physiological stress and reducing feeding efficiency. These significant adverse effects should be highly considered in the Old Mitchell Mine site.

    Across all three proposed mine sites, significant vegetation removal and forest clearcutting, will be taking place as part of the redevelopment of the mine sites. The scale of this disturbance could result in the loss or fragmentation of important habitat used by migratory birds, bats, and other wildlife species for breeding, nesting, foraging, shelter, and seasonal migration. These impacts are particularly concerning for species that are federally protected or identified as endangered species. Based on open source observations from sources including iNaturalist, eBird, and Merlin Bird ID, the following migratory bird species have been documented within or near the proposed mine areas: Barn Swallow, Common Nighthawk, Olive-sided Flycatcher, Canada Warbler, Bank Swallow, Eastern Wood-Pewee, and Evening Grosbeak. Another concern for habitat loss are bat species like the Tri-colored Bat, Little Brown Myotis, Eastern Red Bat, and Silver-haired Bat that may be in the area and could also face increased risks from habitat loss or fragmentation, increased nighttime road traffic which could result in higher mortalities, and noise disturbance associated with development activities. 

    With the many potential, and realized impacts of open pit gold mining. I believe it to be crucial that this project be reviewed under the federal assessment process as the potential impacts of this project could be detrimental to the local watersheds, organisms and people who live within the surrounding area of this proposed development.

    With the ever changing nature of our climate and the increased pressures on our native species, more efforts need to be made on our promise to protect 30% of our lands, freshwater and oceans by 2030. For the future of our youth of tomorrow, we need to act accordingly, cautiously and ensure proper federal environmental reviews are undertaken on large projects like the proposed 15-Mile processing hub project in eastern Nova Scotia. We must be cautious of short-term benefits being traded off for significant long-term environmental impacts.  

Thank you for your time,

Nick Levangie

Note: I do not speak for the people of Mi'kma'ki, however I understand the importance of their ecological knowledge and the importance of Etuaptmumk (Two-Eyed Seeing) and felt it important to include a Mi’kmaw Ecological Knowledge Study that had been shared to me on the Cochrane Hill Gold Development Project by Atlantic Gold Corporation.