May 20, 2021
Honourable Sean Fraser,
Parliamentary Secretary to the Deputy Prime Minister and Minister of Finance and to the Minister of Middle Class Prosperity and Associate Minister of Finance
Re Atlantic Gold’s Proposal for Touquoy Mine Modifications
Dear Mr. Fraser,
I am writing on behalf of the St. Mary’s River Association, to express concern with Atlantic Gold’s request that some changes to their Touquoy mine be considered under a Provincial Class 1 Environmental Assessment. We feel this sets a dangerous precedent that could impact the Environmental process used for other mining and major resource development projects throughout the province.
Resource development like open pit mines have the potential to create major environmental issues through run-off, leaching of toxic materials, etc. and require a full and careful environmental assessment. By allowing “add-ons” or changes to fall under what the public may feel is a different process may encourage developers to submit their projects on a piecemeal basis. The public needs to have confidence that all aspects of the project receive a detailed assessment that would be required by a federal review. The public needs to be comfortable that developers are putting all information on the table and not holding back parts of their project with the hope that it can be approved at a later date under a different process.
We should not have to wonder if a proponent has left certain aspects of a project out with a plan to have them approved separately at a future date. In fact, at this point Atlantic Gold’s project has changed considerably. The modifications which would currently fall under the Provincial Class 1 Environmental Assessment requested do not consider all the changes in Atlantic Golds production plan. These changes to the entire production plan when implemented would be a substantial addition to the project. The addition of three new open pit production sites which would transport ore to Touquoy’s processing facility dramatically change the magnitude of the project. It is important to ensure that all aspects of a project be considered by the same process and hopefully before a shovel is put in the ground.
I am sure the proponent would argue that by themselves the proposed changes are minor and that the three additional open pit mine production facilities are separate projects, but as part of a mine operation of the scale of Touquoy with the addition of three new sites, they could well compound the environmental issues the entire mine operation would have on the surrounding area. Cumulative effects of all sites must be considered. The current assessment plan will neglect the broader environmental risks associated with the proximity of 4 mine sites all connected by the proposed haul roads, dust, and wildlife corridors etc. Because of the significant negative impact some mines have had on the environment, even minor operating plan changes should trigger a complete federal environmental assessment. Anything less gives the public the impression that something could be slipped by with less than diligent oversight.
Thank you for considering the SMRA request to have all major resource development project (including changes) fall under the requirements of a Federal Assessment process.
Scott Beaver, President St. Mary’s River Association
Sherbrooke, Nova Scotia BOJ3C0
Note: the Saint Mary’s River Association is asking that people concerned about the changes to the Touquoy Mine project contact local Member of Parliament Sean Fraser or Jonathan Wilkinson, the federal Minister of Environment and Climate Change.
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