This the Revised Environmental Impact Statement as submitted to CEAA for the proposed Beaver Dam Gold Mine. This final document took well over 20 months to complete.
CEAA statement: “The Agency has conducted a focused conformity review and has verified that the revised EIS conforms to the federal EIS guidelines and IRs. Today, April 1, 2019, marks the start of the technical review period. There is no formal public participation period for the review of the IR responses. However, stakeholders may review and provide comment until April 19, 2019 on whether they feel the information is sufficient, or if additional IRs are required”.
This document provides insights into what the Cochrane Hill EIS statement will look like.
Below are some insightful comments provided by a concerned citizen on the revised Beaver Dam EIS. Review the draft Cochrane Hill EIS when available for public comment and ensure that you submit your comments to CEAA regarding any deficiencies, inconsistencies and misinformation etc. that you may notice.
“You indicted that comments are accepted on the revised EIS material for this project. I take note that:
- I read in Table 6.7.18 at page 314, the Proponent expects no operating water treatment in the reclamation or afterward stage. That stage is cited as 1-2 years. This is not consistent with other technical appendices submitted.
- In the supporting Appendix G.4, post closure conditions for emitted water were presumed to to be more than 8 years after operations end. One of the assumed operating conditions was that the pit had filled with ground water. Other Appendices estimated that it could take up to 13 years for the pit to fill to the expected level.
- Page 318 and appended analysis report that toxic levels of certain metals will likely be released in site water runoff, post operations, unless water treatment is performed. This requirement does not occur during the operations period. So the Proponent is expected to make additional capital investments after the site is closed, and incur water facility operating costs for an indefinite future period. Contradicting their own experts opinion, the Proponent merely asserts it to be unlikely.
- The Appendix G.7 concept plan to provide such water treatment, has the following operational requirements;
- continuous electric power supply of system operation,
- continuous internet services for monitoring and alarms,
- manual, operator service every three days (given the suggested treatment sludge storage capacity).
- year round and winter access by road to the remote treatment facility (for operator and supply delivery), via the 7.2 km private, woods road that services only the former mine site from Highway 224 .
The means to finance and ensure the treatment of toxic runoff water from the former mine site, for 15 – 50 years after the mine project as whole will have ceased, is not adequately provided for in the EIS”. The reclamation bond costs will have had to factor these costs in, did it?
The Eastern Shore Forestry Watch Association response to the final Beaver Dam Environmental Impact Statement. Insightful and helpful comments. E.g. …..
184.108.40.206 Waste Rock Management: There is a description of the stockpiling of waste rock at the Beaver Dam Mine Site but no information on geochemistry of this material. ESFWA:More information is required on the geochemistry of the waste rock and possible leaching of arsenic from these piles. This would be similar to the low grade ore that is planned to be stockpiled on surface at Cochrane Hill, it would be subject to leaching.
220.127.116.11 Infrastructure failure: The EIS states “Portions of all phases of the Project have the potential for infrastructure failure. Infrastructure at the Beaver Dam Mine Site will be minimal and given the short life of the Project, failure should not occur without being caused by extreme natural causes, such as a hurricane or earthquake, or human error.” ESFWA: More information is needed describing how the Proponent will attempt to minimize the risk created by these natural causes which do occur in Nova Scotia, and human errors which are most likely to occur during the life of the project anyway.
6.6.4 Consideration of Consultation and Engagement Results: ESFWA: More information is required to illustrate that community responses were incorporated into the revised EIS. This is exactly what I anticipated would happen with stakeholder concerns with respect to redesigning the Cochrane Hill Gold Mine. Document what you ask and keep a record of responses if any, regarding design changes.
Atlantic Gold – Atlantic Mining NS. Corp. has three environmental permit applications before the CEAA for their String Of Pearls satellite mines (Fifteen Mile Gold Stream, Beaver Dam, and Cochrane Hill). It is an onerous task to complete one EIS satisfactorily and keep on top of 69 Industrial permits(at Touquoy Mine Site) and it is another matter to take on two additional environmental impact statements. When the draft EIS for Cochrane Hill is available, compare it to the Beaver Dam EIS document. One should be looking for missing baseline data, up to date data, misinformation, missing information, inconsistencies, dismissive comments such as the example noted above, cost cutting measures at the expense of the environment, motherhood statements not supported by facts, lack of demonstration of “economical not feasible” or “technically not viable”.