Fifteen Mile Stream proposed gold mine project – Submit your comments by April 30
Fifteen Mile Stream is both the name of a stream on the Eastern Shore, and the name of a proposed open pit gold mine project, now open for public comment.
Atlantic Gold (the gold mine project proponent) is proposing to build and operate an open pit gold mine at the Fifteen Mile Stream, located in a wetland-rich area approximately 95 kilometers northeast of Halifax, Nova Scotia. The partially processed ore from Fifteen Mile Stream would be trucked to the Touquoy mine, 75 kilometers away, using public roads, including Highway 7, for further processing. The operating period for the mine site is an estimated 7 years, but the contamination from the site will have to be managed forever.
The public comment period on the environmental impact statement (EIS) for the Fifteen Mile Stream project is open until April 30, 2021. Public comments can make a difference and everyone’s submissions are helpful! Asking lots of questions in public comments can also help to slow down the approval process.
CLICK HERE to access the full Environmental Impact Statement for Fifteen Mile Stream. A person doesn't need to read and analyze the whole document to comment. Anyone can hone in on subjects that matter to them most. Below, we have highlighted the issues we find more egregious from an environmental point of view. We welcome you to use these points to help form your own submission.
Please CLICK HERE to submit your comments before the April 30 deadline!
Climate Change Impacts
The area of the proposed mine site is rich in wetlands and biodiversity. Should this area be destroyed, the local natural environment's ability to mitigate harms from climate change will also be lost. To escalate matters, the activities associated with the mine site, including both construction and operations, will contribute to climate change. There is also concern that the climate change impacts expected in Nova Scotia during the next couple of decades will increase the risks associated with the mining activities. For example, with the increase of precipitation and severe storms (e.g., hurricanes) expected in the province the risks associated with tailings ponds failures may also increase.
Of specific concern, the use of public roads (and the haul road that Atlantic Gold is proposing to build) need proper consideration in the discussion around climate change. Atlantic Gold estimates that 6 million liters of diesel per year will be needed to operate the trucks for the Fifteen Mile Stream project. This diesel, as well as the needed gasoline and propane, will be delivered by tanker trucks and stored on site. In addition to emissions from the trucks, the destruction of wetlands during construction, risks of transporting contaminated ore, impacts from dust and noise, and water waste from washing the trucks after each trip, are all ways in which the haul road will negatively impact the local environment and contribute to climate change. The trucks transporting the contaminated ore to the Touquoy mine would drive past schools, churches, local businesses and hundreds of homes and cottages.
Biodiversity Impacts (Lichens, Moose, and Birds)
Nova Scotia’s provincial lichen, Blue Felt Lichen, has been found at the Fifteen Mile Stream site, along with several other rare lichen species. However, Atlantic Gold states that this is not a problem, and that they will move the Blue Felt Lichen to another spot! Moving (translocating) a lichen and observing that it keeps surviving has not been accomplished in Nova Scotia before, and there’s reason to think it would be unsuccessful (for the lichen). We are calling on the proponent to provide evidence as to why the lichen should be moved at all, and to reference research that translocating this lichen could be successful.
There were 28 observations of endangered Mainland Moose in and around the Fifteen Mile Stream site during site surveys. The proponent does not commit to avoiding known moose shelter sites that were identified by Department of Lands and Forestry. The company needs to do better than this given the multiple observations of this Endangered species and the dire situation the species is in!
Eighty-nine species of migratory birds were observed at the site, which makes it a fairly high bird diversity site. Of these, 16 species use intact interior forest, which is found at the site. Despite the known impacts to birds from noise and light pollution, not to mention direct mortality from collisions with vehicles and during site construction, the proponent states that with their mitigation strategies in place, there will be no significant adverse effect on birds! We will challenge this assumption.
Water and Wetland Impacts
The proposed alterations to the natural water systems and water features are significant in both size and impact. For example, due to the mining activities, Atlantic Gold estimates that the local water table will not return to normal levels for 100 years.
Atlantic Gold is also proposing to realign Seloam Brook around the open pit. Seloam Brook will be realigned through the construction of a 1.6 km raised perimeter berm through an approximate 800m constructed realignment channel. If this should fail, not only will this be destructive to Seloam Brook and disrupt the local hydrological cycle, but fish habitat will also be lost.
In total, Atlantic Gold wants to alter 336 wetlands either completely or partially. 690,817.164m2 of wetlands will be destroyed; this equates to the size of over 552 Olympic swimming pools.
Globally, over 64% of wetlands have been lost due to human activity, and as we lose wetlands, we also lose their incredible benefits and services that they provide to both humans and the natural environment. A GPI Atlantic study (2000) on Nova Scotia’s water resource value showed that wetlands provide an estimated $7.9 billion worth of benefits in ecosystem services to Nova Scotians annually. Given that the estimates for the operating phase of the Fifteen Mile Stream is 7 years, we do not believe that these direct impact of mining activities, and additional indirect impacts, are appropriate or justified.
Within these wetlands, 8 species at risk have been observed; these species include: Blue Felt Lichen, Mainland Moose, Olive-sided Flycatcher, Evening Grosbeak, Eastern Wood-pewee, Rusty Blackbird, Canada Warbler, and Common Nighthawk. In the EIS, the proponent argues that these species can just “leave,” the area, and so no significant adverse effect would take place. In the case of the one immobile species (Blue Felt Lichen, Nova Scotia’s provincial lichen!), the proponent would remove the lichen and put it somewhere else! This is inconsistent with the Nova Scotia’s Wetland Conservation Policy; the wetlands with Blue Felt Lichen are classified at Wetlands of Special Significance, and therefore, are not eligible to be altered or destroyed.
Atlantic Gold argues that other suitable wildlife habitat exists in the proposed site and in the surrounding area. We are concerned that the destruction of wetlands and the subsequent construction and mining activities that will take place at the site will have direct and indirect impacts on these species at risk and the overall local ecosystems and biodiversity.
Please comment on the things YOU are concerned about in the Fifteen Mile Stream Environmental Impact Statement. Send your comments to email@example.com, or submit your comment on the federal government’s website about Fifteen Mile Stream (your comments become public and you must create an account).
Ecology Action Centre will send in our submission, covering the topics described above and more. You can read our submission here.