Public Comments Submission for 15 Mile Gold Processing Hub project #90533

To The Canadian Impact Assessment Registry,

I am writing to express my support of a Federal Impact Assessment through IAAC for the 15 Mile Gold Processing Hub Project in Nova Scotia, CIAR reference number 90533. I am also writing to express  concerns about the project as follows: 

St Barbara is an Unreliable Proponent

St Barbara Limited has NOT been a reliable proponent or good environmental steward during their Touquay gold mine operations in NS. 

To start, St Barbara Ltd did not stick to the agreed approval plan. In the five years between 2018 and 2023, the NS government granted St Barbara Ltd 17 amendments to their original approval for operating the Touquay gold mine  https://www.cbc.ca/news/canada/nova-scotia/gold-mining-company-nova-scotia-supreme-court-1.7298586

Of more concern, in September 2020, St Barbara Atlantic Operations was charged by the NS provincial government with 32 offenses of the Environment Act.  https://www.halifaxexaminer.ca/economy/natural-resources/mining/atlantic-gold-sentenced-to-250000-fines-and-penalties-after-pleading-guilty-to-federal-and-provincial-environmental-charges/ . These included 13 Sediment Releases into a fish-bearing waterway during an 18 month period in 2018/2019. In 2021, St Barbara Ltd was also charged with Federal offenses  https://www.halifaxexaminer.ca/economy/natural-resources/mining/atlantic-gold-sentenced-to-250000-fines-and-penalties-after-pleading-guilty-to-federal-and-provincial-environmental-charges/   for failing to report these sediment releases to the federal regulator.  https://stbarbaragold.ca/environmental-charges/  In 2022, St Barbara Ltd (Atlantic Mining) was found guilty and fined $250,000. 

In 2021, St Barbara Ltd ignored the concerns of local citizens who reported a leak at the tailings dam.  https://www.halifaxexaminer.ca/economy/natural-resources/mining/photos-suggest-that-there-is-a-tailings-leak-at-atlantic-golds-moose-river-gold-mine/  As per the media article, a mining hydrology expert expressed concerns about possible contamination into the surrounding environment and/or possible internal erosion risking a structural collapse of the tailings dam. He advised immediate action. Instead of repairing the leaking dam, St Barbara Ltd’s response was to deny that the orange liquid pool seen in the photos was leaking from the tailings dam even though they were pumping that liquid back into the dam. Social Media posts with updated 2025 drone footage showed that the leaking continues. Concerned citizens also gathered photographic documentation of pollution downstream of Touquay Mine extending to Fish River and Scraggy Lake, even paying, themselves, for water testing that St Barbara Ltd would not. In fact, following closure of the Touquay mine in 2023, St Barbara Ltd missed provincial deadlines to achieve the Province’s expected water quality standards for the area around the mine. As a result, in 2024, the Minister of Environment and Climate Change ordered St Barbara Ltd to pay an $80 million clean-up bond. They paid half but refused to pay the remainder and appealed the order in Provincial Court, threatening further appeals if they lost.  https://www.canadianminingjournal.com/news/atlantic-mining-to-pay-nova-scotia-80m-gold-mine-clean-up-bond-as-it-appeals-conditions/   St Barbara Ltd didn’t pay the remaining $40 million owing on the cleanup bond until 2025.  https://www.cbc.ca/news/canada/nova-scotia/st-barbara-wants-to-sell-atlantic-gold-operations-1.7455908 

Later in 2025, St Barbara Ltd proposed that, instead of cleaning up the Touquay mine site, they would construct a Hydro Energy Storage system that would pump existing heavily contaminated tailings wastewater to a newly created upper level of the former open pit mine during cheaper off-peak hours and then let that water flow through turbines to a lower level, generating electricity. The Hydro Project was expected to run for 50 - 100 years. This environmentally risky cleanup delay tactic was rejected.  https://www.cbc.ca/news/canada/nova-scotia/mining-energy-companies-say-hydro-storage-project-could-be-template-for-n-s-mines-1.7553746  There was no mention of the 2008 requirement St Barbara Ltd had to fund a natural park area beside the mine site in their Hydro Energy Storage Project presentation to Halifax Regional Municipal Council, nor could I find any reference to it in the current  “15 Mile Gold Process Hub Initial Description ” document.

None of this represents responsible behavior on the part of a proponent, especially one proposing to scale up their existing operations by adding three more sites stretching across a broad geographic area spanning Halifax Regional Municipality and the Municipal District of Guysborough. Given the proponents recent actions, this project presents unacceptable environmental and economic risks for future generations of Nova Scotians, and would only add to the toxic legacy of historic gold mining in this province: 

“The Nova Scotia Department of Natural Resources and Renewables (NRR) has identified 219 historical mineral processing sites throughout the province which likely contain mine tailings. The ore processed at most of the sites (194) was gold…”   https://novascotia.ca/natr/meb/download/dp533.asp

A CBC, July 4, 2022, article titled, “Province releases risk ranking of [69] potentially contaminated old mines. Most of the sites with the highest risk scores are former gold mining sites” notes that the list does not include contamination from old mines on private property. The cost for cleanup of only 2 historic sites, Montague Gold Mines (#1) in Dartmouth, HRM and Goldenville (#5) near Sherbrooke is “estimated to be at least $60 million but that figure is expected to rise”. 

https://www.cbc.ca/news/canada/nova-scotia/risk-ranking-contaminated-historical-mines-1.6509475

Abandoning mines, leaving the pollution to spread unchecked, and forcing taxpayers to foot the cleanup bill, is a pattern of mining corporate misbehavior Nova Scotians have come to expect but do not want or deserve. Gold is not a critical mineral. There is more gold stored in vaults than the world will ever use for medical or other necessary purposes. And where is the provincial wealth that the nearly 200 gold mines were supposed to bring? Exaggerated claims of economic benefit, rock-bottom royalty rates, increasing risk of tailing dam leaks and/or failures due to climate change related heavy rain events, in a province where 40% of the population relies on water from a well, lake or river, means gold mining is not worth the risks. Repeating something that ends in the same results, over and over while expecting a different outcome is the definition of irresponsible government. Nova Scotians deserve better. 

Cumulative Effects of Development in The District of Guysborough

The only cumulative effects St Barbara mentions in their “ 15 Mile Gold Processing Hub Initial Project Description, Plain Language Summary ” is the historic legacy of toxic pollution on the four proposed sites. There is no mention of the cumulative negative impacts of this project in combination with all the other approved heavy industry project development planned for the Municipal District of Guysborough. Here is a list of those I am aware of, although there may well be others: 

Three Onshore Wind Farms

There are three wind farms planned for the District of Guysborough. One wind farm, Ocean Lake Wind, just approved on July 3, 2026, is the largest to date in NS, with up to 158 turbines. Onshore wind farms come with extensive road networks that will disrupt and fragment forest and wetland habitat for wildlife including Species At Risk. The electricity generated from the three wind farms will be used by Everwind Fuels to produce hydrogen and ammonia, rather than to green NS’s dirty coal-fueled grid.    Burning coal, oil, diesel and methane gas creates pollution that increases heart and lung diseases, which strains our struggling healthcare system. 

Hydrogen and Ammonia Production Plant

Everwind Green Fuels Hydrogen and Ammonia Facility at Point Tupper, was approved in 2023 and expects to open in 2028. The hydrogen and ammonia will be produced using massive amounts of fresh water, already scarce in Guysborough County, along with the majority of electricity from the three planned onshore wind projects, all to make a clean fuel that will be exported to European markets rather than used in NS. So again, we will get all of the risks and few of the benefits.

Offshore Wind Projects

Three of the five newly announced Offshore Wind License Areas are in Guysborough County coastal waters. French Bank, Middle Bank, and parts of Sable Island Bank will require clearcutting of forested areas for lay-down, marshaling, storage and construction. The first phase of West Wind is for 5MW involving approximately 200 turbines. The NS Minister of Energy confirmed last week on CBC Radio that NS will NOT be receiving electricity from any offshore wind project. Instead, the cables will run west to Quebec and south to the eastern USA, bypassing our grid. Nova Scotians will not be benefiting despite shouldering the associated negative environmental impact to our forests, wetlands, marine habitat and wildlife.  https://cdn.cnsoer.ca/sites/default/files/2025-07/offshore-wind-energy-areas-summary.pdf

Canso Spaceport

Maritime Launch Services Spaceport, in Canso, Guysborough County had its first experimental launch in June of this year. Two launches were planned but only one was completed as the rocket (built without a guidance system) veered off course and flew over Cape Breton rather than the Atlantic ocean as intended. A German Company just announced today, July 7the, 2026, that they were building a $100 million facility at Maritime Launch Services- which is a private for-profit company receiving considerable subsidies from the Canadian government. The risks are such that Guysborough area residents expect to be routinely evacuated for the larger launches.  https://www.saltwire.com/nova-scotia/german-company-to-build-100-million-rocket-launch-facility-at-spaceport-nova-scotia-in-canso

Black Point Aggregate Mine and Marine Terminal

Vulcan Materials Corp, Black Point Aggregates Inc/ Morten Resources

proposed a granite quarry at Black Point in Guysborough County, Nova Scotia, and the construction and operation of a 200 metre-long marine terminal and load-out facility, adjacent to the quarry, in Chedabucto Bay. The quarry is expected to have a production capacity of up to 7.5 million tonnes of granite per year, over a mine life of approximately 50 years. The Minister has authorized repeated extensions for the commencement of work, the latest expiring April 26, 2026 but was probably renewed. 

https://novascotia.ca/nse/ea/black-point-quarry.asp

Speculation on Additional Gold Mines

St Baraba Ltd is looking at the 15 Mile Gold Processing Hub project as an exploration opportunity for even more gold mines in Guysborough County: 

“…this hub could anchor further satellite deposits in Guysborough County if permitting holds.  https://www.geomechanics.io/news/article/touquoy-mine-reboot-stockpile-plan-and-inpit-tailings-explained-for-engineers

All of this is to say that the environmental assessment for the 15 Mile Gold Processing Hub Project needs to be considered in the context of the cumulative impacts to the environment of all of the upcoming developments planned for Guysborough County. 

Loss of Public Trust in NS Provincial Regulators

St Barbara Ltd’s reliance on environmental approvals, monitoring and enforcement by the Wildlife specialists at The NS Department of Natural Resources will be much more difficult since the NS government “reorganized” in March 2026. Premier Houston eliminated the Wildlife Division and fired several managers including the Manager of Biodiversity. A great deal of institutional knowledge has been lost. It is unclear to me how the remaining Biologists could possibly have the same influence over approval decisions, as when they worked in a separate Wildlife Division where their sign-off was required. Adding to the DNR changes, are staff reductions at the NS Department of Environment and Climate Change, deregulation of environmental protections, and new ministerial powers to fast track resource projects. As a result, public trust in these institutions has been shaken. It will take a federal assessment with strong federal input into the monitoring and enforcement components to restore public faith in the project approval process. 

Social Impacts

Contacts within NS labour organizations have told me that St Barbara Ltd intends to build and operate a MINING CAMP for employees of the 15 Mile Gold Processing Hub project. There are known social impacts to these kinds of industrial camps including increases in drug use, criminal drug trade, sexual assault and human trafficking. Negative social impacts of mining camps on Indigenous communities were well documented during the National Inquiry into Missing and Murdered Indigenous Women and Girls. It is not clear that St-Barbara Ltd has been open with the public or Indigenous communities about their intensions to have a camp. I certainly don’t see any measures outlined in the project description summary report to mitigate the associated harms. I will add, as a final point, that attempts by St Barbara Ltd to keep their camp drug-free, will be challenging given the proximity of the four mine sites to many local towns. 

Thank you for the opportunity to express my support for a federal assessment through IAAC and to outline my concerns about the project proponent, cumulative effects, provincial deregulation and social impacts. 

With Regards,

Karen Robb

HRM NS