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Elizabeth May addresses
The Focus Report

Dec 24, 2008

Response From The Green Party Of Canada To The Focus Report Touquoy Gold Project Moose River Gold Mines, Nova Socita
December 24, 2007

Prepared by

Elizabeth E. May, O.C.
Green Party of Canada


The Green Party of Canada is a federal political party founded in 1983. Our core principles embrace ecological sustainability and economic health, among six key pillars, including human rights, non-violence, and economic justice. The Central Nova Electoral District Association covers the area including Moose River and all our members within the riding.

It may be unusual for a political party to present a submission for a Focus Report in a Class 1 Provincial Environmental Assessment. In this case, I felt strongly that we should as the proposed project represents the antithesis of ecological sustainability and fails to meet minimum tests for economic health.

My relevant background to review the Environmental Impact Statement is having practiced environmental law (admitted to the bars of Nova Scotia and Ontario, currently not practicing), serving as Senior Policy Advisor to the federal Minister of Environment from 1986-1988 during which time one of my responsibilities was working with Environment Canada to obtain approval for legislating what was then a Guideline Order of Privy Council mandating the Environmental Assessment Review Process, that I resigned my position when the EARP was violated in the approval of permits for two dams in Saskatchewan, and having participated in dozens of environmental reviews, starting with the first EARP in 1974, of the Wreck Cove Hydroelectric project in Cape Breton. I do not claim to be an expert in any specific area of science, but I have formed expertise in the process and in the increasingly corrupted practice of EA.

I have a growing concern that environmental assessment risks becoming a pointless exercise due to the abuse of process by a series of proponents. Increasingly, it seems an exercise in wasting money, producing volumes of paper without useful information, and wastes valuable volunteer and public effort, not to mention the value for money from the point of view of the taxpayer. Generally, environmental assessment, when properly undertaken is designed to play a constructive role in project planning, allowing for alterations of a project to reduce impacts where possible.

The flaw in environmental assessment in Canada has always been the acceptance of "self-assessment" and the preparation of the EIS by the proponent. Over time, this flaw has worsened. Proponents increasingly churn out overly lengthy impact statements with the apparent intention of discouraging public participation through the intimidating weight of material. Environmental consulting firms tend to have developed a formulaic approach -- all impacts can be mitigated. There is no such thing as a finding of a significant environmental impact that cannot be mitigated.

On behalf of the Green Party of Canada Central Nova Electoral District Association, I have reviewed the Focus Report and all the appendices prepared by Conestoga-Rovers for DDV Gold Ltd, a wholly owned subsidiary of Atlantic Gold, an Australian mining company.

This response will address the following issues of concern:

  1. The inherent unfairness of the review process
  2. Whether the proponent met the requirements of the Terms of Reference:
    a) socio-economic impacts (complete failure to examine the impact of a boom and bust project of five years' duration)
    b) failure to assess adequately the risks of developing a gold mine in an area with a legacy of toxic mine waste
    c) failure to address air quality and climate change adequately
    d) Other observations.

1) The inherent unfairness of the review process

In the view of the Green Party Central Nova EDA, I wish to state in the strongest possible terms that the process offends basic principles of natural justice. It is unfair to have provided large amounts of technical material for only a 30 day period with a deadline of Christmas Eve. Most of those affected by the proposed mine and opposed to its development are local residents and volunteers. The refusal to extend the deadline is inherently unfair. According to media sources, the reason for the refusal was that it would be unfair to the proponent to give citizens time to enjoy Christmas holidays. If this region were largely non-Christian in origin, perhaps this attitude of government could be better understood. Nova Scotia is a traditionally a largely Christian province, with other religious traditions made welcome. Christmas holidays are a significant time for Nova Scotia families. Preparation of the response to the Focus Report by December 24th is an affront to democracy.

We wish our official protest to be noted.

In addition, this project should have been subjected to a joint Federal-Provincial assessment at the level of a Comprehensive Study under the Canadian Environmental Assessment Act. The proposed gold mine and processing plant trigger the federal Act. Gold mines with a production capacity of 600 t/day are required to undergo a Comprehensive Study. This is a recent addition to the Comprehensive Study list, based on the recent "Red Chris" decision. DDV plans are for a production capacity of 4500 t/day (FR 1.2, page 1), and therefore a federal review under CEAA is required by law.

It seems incomprehensible that an environmental review of this project could have progressed so far without recognizing that it requires both a federal and a provincial review.

2) Whether the proponent met the requirements of the Terms of Reference

There are a number of areas where the Focus Report glosses over or skips important areas that were required by the Minister's letter of April 10, 2007 and the Terms of Reference prepared by the Nova Scotia Department of Environment and Labour of May 7, 2007. .

a) Socio-economic impacts

Section 4.0 of the TOR required an assessment of socio-economic impacts. The Focus Report mentions only positive impacts and those are presented as hypotheticals. The Focus Report imagines that the proponent will contribute to local charities, will build facilities that will remain when the mine is closed. These are not stated as commitments but as potential only.

The Focus Report fails totally to address the large and likely negative impact of a project of such short duration on local socio-economic conditions of neighbouring communities. If the project were of several decades, the failure to discuss the impacts on the local community of its eventual closure in socio-economic terms would be easier to understand. In this case, according to the proponent, the mine will operate for only 5-7 years (Section 6.3 of the Focus Report, and Appendix E, p.1). In that period, as many as 150 people will be employed: 70 in mining, 50 in processing and 30 in management. It is hard to be sure what the full time employment will actually be. While Appendix E and Section 6.3 of the Focus Report refer to the 150 job figure, the anticipated number of vehicles projects only 50 cars a day (30 on day shift and 20 on night shift). (Section 6.3.4, p. 196).

The area has very low population levels. The proponent believes the biggest socio-economic impact is in the complete removal of the existing community. This is clearly a large and serious impact, especially for those residents who will be forced to re-locate. There are eight full time residents in four homes. There is no discussion of the views of these people whose lives will be completely uprooted.

Nevertheless, the complete failure to even discuss the impact on the community of bringing in an outside labour force and then leaving that group of people unemployed within as little as five years is unacceptable.

Most environmental assessments dealing with new projects in areas where population is low outline the socio-economic impact of a non-local labour force, construction workers and others drawn to the project. Most environmental assessments (for projects in the Athabasca tar sands, Mackenzie gas pipeline project, etc) detail the expected increases in crime, exposure to drugs, HIV-AIDS and other social problems associated with a transient workforce in a remote community. While Moose River is technically within the range of the Halifax Dartmouth Region, it is a small community located within a region of other small communities. The workforce brought in for the duration of the project will have an impact on the fabric of the community for good or ill. That issue is simply ignored by the Focus Report.

The Eastern Shore has been developing to capitalize on its natural beauty. The Candidate Wilderness Area at Ship Harbour Long Lake builds on and accelerates the investment in the Eastern Shore as a destination area, marked by wilderness values, coastal protection and a diversified tourist infrastructure. It has been attracting new, small business people have been investing in operations catering to tourists. The route, known as the Lighthouse Route , has had a number of foundation businesses over a long period. Classic operations such as Liscombe Lodge, and the Krauch Smoked Salmon have been attracting tourists for decades. Building on that, new operations have been appearing. Bed and Breakfast operations, antique stores, cafes, and inns in the area would all be at risk from the industrialization of the Moose River area. Increased truck traffic, some carrying dangerous goods, trucking in cyanide, trucking out product, and the disruption throughout construction would all reduce the viability of the area as a tourist destination. The careful efforts of independent entrepreneurs would be put at risk for as little as a five year operation. The proponent has ignored this risk entirely in preparing its Focus Report.

Many local people are hoping for employment, but many will lack the appropriate skills for the more technical and managerial aspects of operations. Given the short duration of operations, and the fact the parent company is from Australia, it seems highly likely that jobs in management will transfer from Australia for the duration of operations. Other workers, however, are likely to move into the area and then find themselves unemployed with the mine's closure.

The impacts of "boom and bust" cycles in socio-economic terms are generally seen as negative. They do not advance healthy and sustainable communities. Boom and bust operations are disruptive of the fabric of community. Half as many jobs created in ways that ensure long-term employment are of far greater benefit to the society, in both social and economic terms.

The Focus Report cannot be accepted as submitted for the weakness of the socio-economic analysis. As discussed, it completely omits any discussion of the following:

· the current value and potential of existing industries in the area and the threat posed by the Touquoy Mine Project,
· the impact of an influx of workers for a period of short duration in terms of social negatives (crime, drugs, HIV-AIDS),
· The complete lack of any analysis of the down sides of boom and bust economic developments.

The Minister is urged to reject the Focus Report as failing to meet the Terms of Reference requirements socio-economic and community impacts. (p.4 TOR)

b) Failure to assess adequately the risks of developing a gold mine in an area with a legacy of toxic mine waste

The Focus Report is written in a benign tone that suggests there will be no adverse environmental impacts. It is only in the appendices and technical reports that the project's largest environmental, health and toxic issues is evident.

The largest environmental problem with the proposed mine is that it will take place in an area already heavily contaminated from historic gold mine operations. The toxicity testing of the water bodies impacted by the project reveal that, according to the Golder water quality modeling, they will be contaminated with toxic chemicals at levels that exceed the CCME (Canadian Council of Ministers of the Environment) Guidelines. (Appendix H, Water Quality Modeling, Golder Associates). Scraggy Lake will be the most heavily contaminated with arsenic, aluminum, cadmium, and copper. The levels of contamination will be higher in summer months, so averaging is questionable in relation to risk assessment. Fish River and Lake Charlotte will also exceed CCME guidelines for these contaminants.

There is an inadequate assessment of the risks of mercury. Mercury is persistent and has health effects at very low levels. The Golder water quality modeling did not assess the risk of mercury contamination at all. The treatment of the mercury threat in the Focus Report and the Appendices is completely inadequate.

The placement of tailings from the historic gold mines is described in Appendix P. Essentially, the open pit mine is to be located in and around the site of six historic gold mines and the toxic legacy of over a century of irresponsible mining. The project description should be approached as one primarily about mining in a toxic waste site, which also happens to be in an important wilderness area.

The approach favoured by the proponent is the least cost option -- "on site containment." (Appendix P, p. 6-7). Yet, by definition, this project will involve disturbing the toxic mess left behind by previous mining operations. The risk of mobilizing mercury, arsenic and other contaminants is very high in the logging, excavating and construction phase, as well as in the continuous mining operations. The safer environmental approach would be to find a permanent solution and off-site disposal of the old tailings.

This approach has been rejected by the proponent primarily because it is viewed as too expensive. The appendix displays the range of options for clean-up in Table No. 1(Ref. No.MO22088-EI). The option of "Leave in place" is described under the "Cost" parameter as "minimal at start up." The one the proponent prefers "on-site containment" strangely has no notation as to cost. The best environmental option, "Off-site disposal", is rated under cost as "High cost for disposal…" It is also noted in the matrix of options that the "leave in place" option is the only one to be noted as having a risk of "Future liability" and "ongoing legacy of ongoing contamination."

It is not at all clear from the Water Quality Modeling in Appendix H whether Golder modeled any contamination from the previous mine tailings. One can infer from the report that modeling only anticipated the contamination from new operations. This is a significant flaw in the modeling. With "on site containment" the proponent's preferred option, the risk of contamination during land clearing, construction and on-going operations is far greater than if this project were taking place in an area without previous contamination. Yet, the water quality modeling has been conducted as though there was no previous contamination.

For the alleged benefits of a five year operation, the significant risk of remobilizing the tons of old tailings, to be mixed with new mine waste entering the local watercourses, is simply unacceptable.

The Minister is urged to reject the Focus Report as failing to meet the Terms of Reference requirements on Impacts to surface and Ground Waters (p. 5 TOR).

c) Failure to address air quality and climate change adequately

The issue section labeled "Air Quality" (section 2.8.4, p. 18) purports to deal with air quality, green house gases and dust form the Open Pit. In fact, the only supporting documentation, Appendix E, deals solely with watering operations to hold down dust. It is deeply troubling that the brief paragraph on air emissions is complete nonsense.

At page 18 of the Focus Report, it is noted:

"Greenhouse gases will be 7,000 tonnes per year which will have negligible effect on air quality in the Project area."

Either the consultant, Conestoga-Rovers, allowed the Focus Report to be written by a scientific illiterate, or they take the public and the Nova Scotia government to be scientifically illiterate. The sentence is absolutely useless and nonsensical. Greenhouse gases (GHG), regardless of volume, do not constitute an air quality impact on a specific area. GHGs are a planetary threat to climate stability. Why is such an insulting claim included in the Focus Report? What is it obscuring?

The next sentence, "Gases generated by blasting will dissipate in the atmosphere within minutes of shooting without any harmful effects," is also rubbish. Does the proponent believe GHG are created by blasting? Blasting will generate dust and particulate matter. Given the existing toxic contamination, blasting may generate particulate matter with arsenic, mercury and cadmium content, with significant threats to human health and the environment. But blasting will not create GHG, barring the use of an internal combustion engine to generate the blast.

If GHG are generated, the rest of the sentence is still nonsense. GHG do not dissipate. GHG have a residence period in the atmosphere of approximately one hundred years (IPCC TOR). It is not their local impact that is significant. It is the cumulative impact of the alteration of GHG concentrations in the atmosphere that threatens massive and cataclysmic climate change. The significance of 7,000 tonnes of GHG/year is in its global, not local impacts. The proponent offers absolutely nothing in the effort to reduce or offset emissions. The Mining Association of Canada has an excellent climate action plan. Perhaps Atlantic Gold, being Australian, is unaware of climate science and the need to reduce emissions. A goal of carbon neutrality would be worth advancing. Surprisingly, the proponent offers nothing but bafflegab in response to the single largest planetary threat of our age.

A section on air quality relating to the Process Plant has no supporting appendices at all, yet deals with the health threats of ammonia and off-gassing of hydrogen cyanide. No information is offered in support of the claim that "Airborne contaminants do not pose a health risk to flora or fauna on or off the site." (p.25) What of worker exposure? Is this not considered a serious issue? What of fugitive emissions?

The paragraph as submitted is not adequate to deal with the issue.

A section on air quality should have reviewed the increase in vehicle emissions, knowing that there is an increasingly large literature on the health risks of diesel exhaust, the potential for air-borne mercury contaminants, the impact of increased greenhouse gases on Nova Scotia's carbon reduction targets, the impact on air quality of the process plant with its emissions of ammonia and hydrogen cyanide.

The Minister is urged to reject the Focus Report as failing to meet the Terms of Reference requirements on air quality.

d) Biodiversity impacts

The Green Party of Canada supports the comments of the Canadian Parks and Wilderness Society regarding threats to Mainland Moose, and of the Ecology Action Centre in regards to the spawning potential of local waterways. In fact, it appears that the impact on fish habitat has been deliberately understated. It is possible this was deliberate in order to avoid triggering greater federal involvement through Department of Fisheries and Oceans.

3) Conclusion:

The proponent was given a full year to respond to the concerns set out through the Minister's letter of April 10, 2007 and the Terms of Reference issued May 7, 2007. The proponent chose to do a "rushed job." When one considers the contracting time involved to retain Conestoga-Rovers and for Conestoga-Rovers in turn to retain Golder and Associates to conduct water quality modeling, CBCL to review the treatment of effluent, Metcon Labs, inNSPEC-SOL, etc, the time available was completely inadequate to prepare a thorough assessment of the range of issue at stake. The haste shows in the haphazard presentation, the many missing elements, and evident guess-work in the Focus Report. On behalf of the Green Party of Central Nova, I have not been able to respond to all the weaknesses and concerns, but combined with the critiques of others a full picture emerges of a project that poses a serious risk to existing economic activity, ecological and potentially human health, for very little benefit. An operation of as little as five years and at most seven is not sufficient inducement for the massive changes that will hit a small community and then be gone. The risk to water quality is of primary importance. The historic contamination combined with the open pit and processing operations pose an unacceptable risk that was inadequately examined by the proponent.

A further fundamental point is that this project should not be approved at the provincial level prior to the completion of the federal review pursuant to the Comprehensive Study List of the Canadian Environmental Assessment Act. While the minister should not approve the project prior to federal review, it is entirely appropriate for the Minister to reject the proposal and avoid the time and expense of a comprehensive study of such an inappropriate development.

We urge the Minister of Environment and Labour to reject Atlantic Gold's application to develop an open pit gold mine and processing plant at Moose River.

Respectfully Submitted,

Elizabeth E. May, LLB, O.C.

Green Party of Canada

Eastern Shore Forest Watch invited May, an Order of Canada recipient and past-President of the Sierra Club of Canada, to call attention to a proposed open pit gold mine in Mooseland, located in the Ship Harbour-Long Lake Wilderness Area and Tangier watershed.

Gail Martin
Editor, Highway 7 Online

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