Written by CCNB Action
Action Alert - Elmtree Property Gold Mine
Action Alert Deadline: Tuesday, April 26, 2011.
The Elmtree Property Gold Mine is a proposed open-pit gold mine in an
environmentally sensitive area near Beresford, NB. The mine, which plans
to operate for 1.5 to 2 years, carries the potential for significant
negative environmental impacts including destroying the headwaters of an
Atlantic salmon stream and impacting the river downstream. The mine
carries the potential for acid mine drainage and could affect the water
supply for the town of Petit Rocher and the water quality and quantity
for nearby residents on wells. Mining could also harm wetland habitats
including uncommon white cedar swamp and culturally important black ash
stands which host several rare plant species.
CCNB Action, Mining Watch Canada, the Belledune Citizens' Committee,
Bathurst Sustainable Development, Sierra Club of Canada-Atlantic, Grand
Lake Watershed Guardians have requested that the Environmental Impact
Assessment for the Elmtree Property Gold Mine be bumped up to a Joint
Panel Review, which would mean greater public participation at both the
federal and provincial levels.
What can you do?
1. Request that the Environmental Impact Assessment for the proposed
Elmtree Property Gold Mine be given Joint Panel Review status. This
request must be sent to the federal and provincial Environment Ministers
and copied to the project manager at the Canadian Environmental
Given the limited economic benefits and potential for significant
impacts to sensitive environmental features including salmon streams,
municipal and private water supplies, and important wetland communities
I support the request by CCNB Action, Mining Watch Canada, the Belledune
Citizens' Committee, Bathurst Sustainable Development, Sierra Club of
Canada-Atlantic, Grand Lake Watershed Guardians to have the project
undergo a joint panel review.
Hon. Peter Kent
Minister of the Environment
401 Confederation Building
House of Commons
Tel: 613 992-0253
Hon. Margaret-Ann Blaney
NB Minister of Environment
P. O. Box 6000
Tel: 506 444-5136
Hon. Gail Shea
Minister of Fisheries and Oceans
House of Commons
Parliament Buildings, Wellington Street
Ottawa, Ontario Canada K1A 0A6
Vanessa Rodrigues, Project Manager
Elmtree Property Gold Mine project
Canadian Environmental Assessment Agency
1801 Hollis Street, Suite 200
Halifax NS B3J 3N4
Tel.: 902 426-0564
2. Make comments to the Draft Environmental Impact Statement (EIS)
Guidelines found here:
Deadline for comments: Tuesday, April 26, 2011.
Concerns with the Draft Environmental Impact Statement:
1. Sustainable development. Contribution to sustainable development is
highly dubious considering the potential for serious environmental
impacts for a project that will involve only 1.5 to 2 years of
employment and potential economic benefits.
2. Alternative Closure Options. In the section regarding alternative
means of carrying out the project (Sec. 4.4.6), the list of requirements
should include alternatives for mine closure and decommissioning.
3. Uncertainty of Success of Mitigation Measures. Realistic estimates of
the likelihood and frequency of malfunctions should be given (Sec.
4.6.1). Factors which contribute to the uncertainty of detecting and
mitigating impacts associated with accidents and malfunctions should be
assessed. An assessment of the degree of uncertainty associated with
proposed mitigation measures (Sec. 4.7) for routine operations and
habitat compensation should be provided.
4. Cumulative Effects. Existing and potential future effects of broader
environmental changes (e.g. climate change) and regional population
trends to important species such as Atlantic Salmon and Black Ash must
5. Follow Up and Monitoring. Costs of short-term monitoring should be
estimated as should any requirements and costs for post-closure
monitoring (Sec. 4.10). The responsibility for long-term monitoring and
if necessary mitigation should be clearly identified.
6. Air Quality. While the guidelines indicate that ore processing is
part of the scope of the project, air emissions from ore processing also
need to be considered within the EIS (Sec. 4.13).
7. Water Quality. In describing the potential impacts of acid rock
drainage and metal leaching on ground and surface water (Sec. 4.14.3,
4.14.4 and 4.14.5) the proponent should be required to describe
variability of the results from tests and modelling conducted, and a
review of the relative success of predicting acid rock drainage and
metal leaching from similar ore bodies.
8. Species at Risk and of Conservation Concern. Evaluation of potential
effects on any of the categories of species described in Section 4.15.4
should consider the relative importance of the Elmtree River for
regional populations and population dynamics, and the diversity of those
9. Mine Closure. We are concerned by the reference to a “conceptual
reclamation and closure plan” in Section 4.15.1. Given the demands
throughout the guidelines to evaluate potential effects and mitigation
measures during and after closure, a conceptual plan is clearly
insufficient. While detailed engineering could be left to a later stage
of permitting, regulators and the public need to know about the closure
plans to a sufficient level of detail to properly review the proposal.
The guidelines should include a higher degree of precision and be
consistent in the requirements for information about closure, namely:
detailed description of activities and timing for mine closure;
rationale for the selection of preferred closure option compared with
other alternatives; cost estimates for closure activities; analysis of
uncertainty associated with closure options including variability in
modelling of key parameters, technological failures etc. and an
explanation of long-term responsibility and stewardship of the site.