Signal Gold, which until recently was called Anaconda Mining (an anaconda is a giant snake that strangles its prey), plans to operate the double-pit gold mine at the southern tip of Gold Brook Lake and on either side of Gold Brook, and process 4,000 tonnes of ore per day, with mine closure to begin in 2036. One of the open pits will be 128 metres below sea level, about twice as deep as Fenwick Towers in Halifax is tall.
Signal is just the latest player to join the rush for gold on Nova Scotia’s Eastern Shore.
Australia’s St Barbara Ltd subsidiary Atlantic Gold and affiliate Atlantic Mining NS already operate one open pit gold mine at Moose River, which is coming to the end of its life. Atlantic Gold wants to open three more mines – at Beaver Dam, Fifteen Mile Stream and Cochrane Hill – which are under evaluation by the Impact Assessment Agency of Canada.
In his letter to Signal Gold CEO Kevin Bullock, Halman wrote that in deciding to approve the mine he had “considered the public interest in this proposed project, the proposed location, and the nature and sensitivity of the surrounding area, and the potential and known adverse effects or environmental effects of the proposed project, including to species at risk or of concern and their habitats.”
“After considering all of the above,” Halman wrote, “I am satisfied that any adverse effects or significant environment effects of the undertaking can be adequately mitigated.” In a separate document, he included broad terms and conditions with which Signal Gold is expected to comply.
But did Halman really read and consider all the environmental risks? Or did he get distracted by the wildly optimistic dollar signs and list of “benefits” that Signal claims the project will bring?
Take, for example, this audacious statement in Signal’s executive summary: “Total household income in NS will increase by nearly $1.1 billion because of the Project.”
Unless the company is planning to pay a lot of provincial taxes that will be distributed to every Nova Scotian household – something that seems unlikely given that Atlantic Gold has yet to pay a single cent of provincial tax despite having produced many hundreds of millions of dollars’ worth of gold since beginning operations in Moose River in 2017 – this statement from Signal seems about as valuable as a lump of fool’s gold. And just as deceptive.
The biggest benefits of such gold mines inevitably flow upwards to investors and executives. A few trickle down to workers and suppliers, while the damages and environmental costs tend to accrue on the ground, and the public winds up paying the high price for them.
A massive amount of reading, and little time to do it
Although Halman may indeed be an extraordinarily fast and competent reader, it seems highly unlikely that he managed to read or even skim through the entire proposal that Signal Gold submitted to his department on June 10, 2022.
Signal’s submission – 26 files in all – is 5,925 pages long.
Nova Scotia environmental assessment regulations require only the quicker and less onerous Class I environmental assessment for metal mines, rather than the longer and more extensive Class II EA required for, among other things, a cement plant or pulp mill.
So Halman had only 50 days to get through that massive submission and make a decision.
The public, the government scientists in Halman’s department, and experts in other provincial and federal government departments had just 30 days to read and comment on the door-stopper of a proposal.
This led several government scientists to admit in their comments that the short time frame in the Class I environmental assessment meant they were unable to study more than small parts of Signal Gold’s proposal.
A senior fisheries biologist from the federal Department of Fisheries and Oceans (DFO) wrote that because of the “limited time period allocated to DFO for review and the extent of the material submitted, the Department could not conduct an extensive review of the entire submission package.”
However, even by looking at just a few parts of the proposal, he found lots to criticize, zeroing in on the plans to alter Gold Brook and other watercourses, and observing that:
… it is likely that DFO’s guidelines for ecological flow requirements for fish and fish habitat will not be met for numerous watercourses within the project area, including Gold Brook.
A “high risk to fish”
The DFO biologist concluded that the “predicted long-term/permanent alterations to the natural flow regime of these watercourses from project activities represent a high risk of impacts to fish and fish habitat, particularly during low flow periods.” [emphasis added]
He also took issue with the modelling used in the Signal Gold submission, saying the models are “not well suited for predicting impacts to fish and fish habitat.” The scientist concluded:
There is high degree of uncertainty regarding the model-based effect predictions in the EARD [environmental assessment registration document], and the proponent has not proposed a viable means of accurately verifying the effect predictions through flow or biological monitoring. [emphasis added]
These criticisms were coming from the federal government, which is not directly involved in the environmental assessment process for the Goldboro gold mine.
Signal Gold avoided a federal impact assessment by setting daily ore production at 4,000 tonnes, basing this on two clauses in Canada’s Impact Assessment Act, which state that a federal impact assessment is required only for:
- any new metal mine with an ore production capacity of 5,000 tonnes per day or more
- the expansion of any existing metal mine if the expansion would result in an increase of mining operations of 50% or more and the total ore production capacity would be 5,000 tonnes per day or more after the expansion
As Signal Gold’s Kevin Bullock told the Halifax Examiner in early 2022, by proposing a daily ore production rate below that threshold, the company was able to avoid going through a longer and more comprehensive federal assessment.
Related: Anaconda joins the gold rush on Nova Scotia’s Eastern Shore. Part 2. Anaconda aims to avoid a federal impact assessment for its proposed open pit gold mine, but some say the whole regulatory process in Canada is “rigged”
Did Halman read what his own scientists wrote?
But it wasn’t just federal scientists who expressed concern about the lack of time for assessing Signal Gold’s proposal, and about the proposal itself.
Scientists in Halman’s own department were also critical.
A wetland water resources specialist in the NSECC wetlands management unit wrote that the short “timeline” for the EA permitted a review of only five of the documents.
But even that limited review uncovered disturbing information about crucial wetlands in the area.
The NSECC wetlands specialist noted that there are 222 freshwater wetlands within the Goldboro mine area, and they cover 330 hectares, or 27% of the entire project site.
Signal Gold identified only 22 of the wetlands as potentially “wetlands of special significance,” or wetlands that are known to support at-risk species as designated under the federal Species At Risk Act or the Nova Scotia Endangered Species Act.
However, the NSECC wetlands specialist countered that species at risk (SAR) were observed in 25 of the wetlands.
“The project will directly impact 112 wetlands of which 56 will be completely altered and 56 partially altered,” wrote the NSECC wetlands specialist, and the total area of wetlands affected will be 96 hectares, including a “minimum of 43 hectares of wetlands of special significance.”
The specialist concluded:
The NS Wetland Conservation Policy (2011) objective is to “manage human activity in or near wetlands, with the goal of no loss in Wetlands of Special Significance (WSS) and the goal of preventing net loss in area and function for other wetlands”. Based on a review of the project, there is a predicted loss of WSS which is not consistent with the NS Wetland Conservation Policy.
The policy allows for alterations to WSS for projects that are considered Necessary Public Function. Necessary Public Function is defined within the NS Wetland Conservation Policy as “A service, utility, role or capacity deemed essential to Nova Scotians. Such functions involve projects that provide public service on a provincial scale. They include public transportation projects, public infrastructure, linear pipeline or transportation corridors or electrical supply infrastructure, projects necessary for public safety and the protection of adjacent properties and infrastructure and land transactions authorized through an Order of Executive Council”.
Maybe Minister Halman didn’t notice that gold mining is not included in that list of “necessary public functions” deemed “essential to Nova Scotians,” for which wetlands of special significance can be altered.
NSECC has a wetlands management unit for good reasons.
Wetlands have always been important, but never more so than they are now in the climate crisis.
Wetlands are crucial in both mitigating and helping us adapt to the climate crisis, preventing carbon from entering the atmosphere when left alone, but giving off greenhouse gases if they are disturbed.
Undisturbed wetlands also provide invaluable ecosystem services, cleaning polluted water, slowing and storing floodwaters, recharging groundwater, and supporting habitat for many difference plant and animal species.
Is gold ‘in the interest of the public good’?
Critical comments also came from NSECC water specialists. One noted that Signal’s EA documents failed to “clearly identify the fate of several waste products associated with ore processing” including arsenic and cyanide, so the “potential environmental effects of these products are unknown.”
NSECC experts also commented that some sections and figures in the Signal proposal are “very difficult to review” and question many of the assertions in the documents submitted for the environmental assessment.
“Considering these questions exist, the potential impacts and overall alterations to these surface water resources are currently at risk of being underestimated,” wrote a NSECC water specialist.
According to one NSECC scientist, a total of 10.7 km on 32 watercourses and one open water feature, with an area of 16 hectares, would be “irreversibly directly impacted” by the mine, and yet “typically NSECC approaches outline that for this type of alteration (e.g. infilling), approvals should be rejected unless the alteration is in the interest of the public good and there are no other reasonable alternatives.” [emphasis added]
Again, unwritten but definitely something that needs to be asked, is whether watercourse alteration for a gold mine is “in the interest of the public good.”
Climate change downplayed
The NSECC climate change division also provided comments critical of the Signal Gold proposal, and its decision to plan its facilities to cope with only a 5% climate change factor, whereas it should be planning for a scaling factor of weather extremes of 14% to align with guidance from Environment and Climate Change Canada.
The NSECC climate change division also noted that the potential greenhouse gas emissions over the life of the project were not “clearly stated,” so it was not possible to know which emissions were and were not included.
Signal Gold downplayed the risks of climate change, cavalierly writing in its submission that “due to the relatively short duration of the Project, and the contingencies added to mine water infrastructure design, climate change is not anticipated to affect the Project.”
As if climate change were something yet to come, as if we were not already in a climate emergency.
Wildlife habitat and biodiversity will be lost
The Department of Natural Resources and Renewables (DNRR) wildlife division also chimed in, observing that the mine area falls “within identified moose core habitat, and the area impacted will be “extensive, encompassing 1055 ha of largely forested habitat of which 410.8 ha will be completely removed for the placement of infrastructure, mining pits, waste rock storage, and the tailings management facility.”
According to DNRR:
This represents a major conversion of wildlife habitat, including habitat for at-risk species, to infrastructure for the long-term (24 project years (EA page 387), 50-70 years for a mature forested landscape to develop). It is unlikely reclamation will result in the complete reversal of the Project effects. Much of this forested area will be permanently converted post remediation to non-forest features.
The DNRR wildlife division concluded:
Compensation for loss of wildlife and at-risk species habitat should be required in the form of a biodiversity offset through land purchase(s) and conveyance to protected area designation(s) to add to the NS government commitment of protecting 20% of NS land and water by 2030. Compensation should account for the type of habitat lost with a like or better requirement and increased compensation required for loss of habitat for species-at-risk.
Mi’kmaq rights at risk
The critical comments were not limited to government scientists and experts, however.
While there were 16 comments from individuals in support of the mine, mostly from people within the mining industry, as well as 11 unsigned identical emails dated June 21, 2023 [sic] applauding the mine that seem to have been sent from Country Harbour, a community just up the road from Goldboro, there were also 16 comments from individuals opposed to the mine proposal, and several more from groups expressing serious concerns about the project.
The Native Council of Nova Scotia wrote that it is “concerned with the extensive alteration of wetlands & wetlands of special significance (WSS) proposed by the project.” The Native Council concluded that “the 90.599 ha of proposed direct wetland impact alone is an unfeasible amount of wetland to reasonably achieve a ‘no net loss’ scenario that would satisfy the 2019 Nova Scotia Wetlands Conservation Policy.”
The Mi’kmaq Rights Initiative (KMKNO) noted that the project would “impact several communities” and their Constitutional rights “to hunt and fish throughout Mi’kma’ki (Unceded land of the Mi’kmaq people).” KMKNO wrote:
As referenced in the Mi’kmaq Ecological Knowledge Study (MEKS), but not limited to, Moose, Atlantic Salmon, American Eel, Brook Trout, Bear, are all found in the project area. There is little consideration in the Environmental Assessment Registration Document (EARD) with respect to impacts this mine will have on the mainland moose population. It is expected that Nova Scotia Environment and Climate Change (NS-ECC) will ensure these species will not be impacted by this proposed project.
KMKNO also stated that the Mi’kmaq Ecological Knowledge was outdated, and that an updated one is required.
The Ecology Action Centre and East Coast Environmental Law (ECELAW) both submitted detailed and pointed critiques of the proposal, which echo some of the concerns of government scientists who reviewed Signal Gold’s proposal.
Yet none of these many detailed critiques deterred Nova Scotia’s environment minister, at least not enough to convince him to ask for more information or a change of plans.
Halman went ahead and approved the Goldboro mine.
‘Behind closed doors’
Asked for her reaction to the minister’s decision, Karen McKendry, wilderness outreach coordinator at the Ecology Action Centre, replied:
The approval of the Goldboro gold mine project has us questioning the whole process of how large, industrial projects get approved in Nova Scotia, AND the behind-closed-doors procedures they go into after that.
For the Environmental Assessment process, the proponent (Signal Gold Inc.) submitted a document, the Environmental Assessment Registration Document, which leaves a lot to be desired. There are many unanswered questions that remain looming from it, yet the Minister of Environment and Climate Change didn’t ask for those to be addressed through an Additional Information document, as he often does. Why rush this through?
The outstanding issues identified by government staff, the public, and Mi’kmaq-led organizations deserve to be addressed before any approval. Instead, the Minister seems to have packaged up many of the unresolved issues and put them in the Terms and Conditions of the Approval. But follow-up on those Terms and Conditions is a process that is away from public view. After approval, the Terms and Conditions can be further changed and modified, without public input. Then there’s the Industrial Approval, which is also modified, repeatedly, behind closed doors. What the public consults on in the Environmental Assessment process is not what gets built, and does not totally dictate how the project will change over the years.
According to McKendry, the whole provincial environmental assessment process is flawed, and not measuring up to more modern environmental assessment processes, like federal ones:
Through the federal process proponents must evaluate aspects like cumulative impacts to the area surrounding the site, which is especially important to analyze for those people who live close to multiple industrial projects. The federal process has more transparency, and it has support for eligible community groups who need to hire experts to help with their public submissions. The Progressive Conservatives in Nova Scotia ran on a platform that committed to small adjustments to the provincial Environmental Assessment process, and they put their commitment in their environmental goals legislation, but I’ve seen no progress towards that yet.
McKendry concluded, “And really it’s an overhaul that’s needed, not a tweak around the edges.”
“Streamlined” environmental assessment process
On July 29, Jennifer Henderson reported for the Examiner that in May this year, Craig Jetson, the CEO of St Barbara Ltd that owns Atlantic Gold and the Moose River mine and is pushing for provincial approval of expansion of that mine and for approval of three more mines in eastern Nova Scotia, jetted in to Nova Scotia and met with Premier Tim Houston and NSECC Minister Halman.
Related: Atlantic Gold’s parent company hints it may halt its Nova Scotia operation. After St Barbara Ltd issued a statement falsely blaming the province for permitting delays, its stock price fell by 14%.
Henderson wrote that after the meeting, Jetson had a conference call with analysts during which he praised Premier Houston as “supportive” and “very encouraging.”
When Henderson asked Houston if Jetson’s description was accurate, if he is comfortable supporting gold mining in Nova Scotia, the premier replied, “I am a supporter of any company that can meet the standards of the province. We have standards and for those who can meet them, I’m a supporter.”
Henderson then reminded Examiner readers that Atlantic Gold was fined $250,000 earlier this year for environmental charges related to silty runoff at its Touquoy mine site in Moose River.
Henderson also asked NSECC minister Halman about Jetson’s comment that he felt encouraged by “a more collaborative permitting process” that Nova Scotia had recently put in place. Henderson reported Halman’s response this way:
Halman told us [reporters] that while the process hasn’t changed it has been “streamlined” to allow a company to receive more than one permit at a time.
Halman says his department has also hired two people to fill two newly created positions called “business relations officers.” Halman says their purpose is to provide one consistent point of contact for companies seeking information about what they need to do to comply with environmental regulations. In some cases, Halman says they need to explain or educate companies who may be unfamiliar with the landscape here.
Which means that Nova Scotia Environment and Climate Change, the province’s regulator and watchdog, now has two “business relations officers” on the inside whose job seems to be to liaise with and help out the companies seeking environmental approvals, just like the one Halman just accorded Signal Gold.
After Halman approved the project, Signal Gold’s CEO Kevin Bullock thanked the minister for his “support” for the Goldboro mine project.
Just as this article was going to press, St Barbara Ltd issued a statement announcing that it had received approval from Nova Scotia Environment and Climate Change to raise the height of the tailings facility at its Atlantic Gold Touquoy mine in Moose River. The company stated that “This approval ensures the continuity of our Atlantic Operations and supports our long-term plan to operate at Touquoy for the next 12 months, until the end of FY23 [fiscal year].” However, NSECC has yet to make the announcement that the approval has been given, nor is this information available on the NSECC website.