Atlantic Mining Nova Scotia (AMNS) looks bound and determined to mine paradise, blast a giant hole deep into the earth at Beaver Dam in a rural part of the Halifax Regional Municipality just over an hour’s drive from downtown Dartmouth, and extract 56 million tonnes of material from the bowels of this small province between 2023 and 2027 in return for a few thousand kilograms of gold.
The open pit gold mine that AMNS foresees is no small thing.
It will cover 632 hectares (1,611 acres, or the equivalent of 1,220 football fields), create a crater nearly a kilometer long, half a kilometre wide, and 200 metres deep — that’s twice as deep as Fenwick Towers in Halifax is tall. Nearly 15 million tonnes of “waste” will be “generated” over the short life of the mine.
The mine will also be just upstream from the Killag River, where the Nova Scotia Salmon Association has been working for years with a host of other organizations and support from the provincial and federal governments, to undo the negative effects of acid rain with lime treatments and restore the watershed to health so it can again support wild Atlantic salmon.
But Beaver Dam is just one of the open pit mines the company has planned for the province.
AMNS already operates one giant open pit gold mine in Moose River, and in addition to the Beaver Dam project that is undergoing a joint federal – provincial assessment, it has two other mines planned for Nova Scotia’s Eastern Shore — at Fifteen Mile Stream, which is also undergoing assessment, and an even more controversial one at Cochrane Hill on the St. Mary’s River.
AMNS describes itself as a “wholly owned subsidiary” of Australia’s St Barbara Ltd, which in 2019 purchased the former owner of these mining projects, Atlantic Gold, for the tidy sum of $722 million.
Because of the purchase and name change, throughout this article, “Atlantic Mining NS,” “AMNS,” and “Atlantic Gold” are used, but all three terms refer to the same entity, just pre- and post-sale.
But here’s a curious thing: since the company began producing gold at the Touquoy mine in Moose River in late 2017, it has produced many hundreds of millions of dollars worth of gold, and yet Extractive Sector Transparency Measures Act (ESTMA) reports filed with the federal government show it hasn’t paid a single cent in taxes to the governments of Canada or Nova Scotia.
Northern Pulp stands to profit, too
And here’s another curious thing.
The land in Beaver Dam where St Barbara intends to produce hundreds of millions more dollars worth of gold for itself and its shareholders belongs to yet another large foreign corporation that should be paying lots of money to Nova Scotia — and isn’t.
The property where the Beaver Dam mine is to be located belongs to the Northern Pulp affiliate Northern Timber.
That Northern Timber land has an interesting history.
It is part of the 475,000 acres that Northern Pulp purchased with a $75 million loan from the province of Nova Scotia.
In 2010, the NDP government of Darrell Dexter provided Northern Pulp with a 30-year loan to buy a huge chunk of land — about 0.3% of the province. (The province immediately repurchased 55,000 acres of that land at 1.7 times the price per acre that Northern Pulp had paid for it, meaning there was a hidden gift of $7 million in that land loan and deal, but that is another story.)
As of 2020, Northern Pulp still owed the people of Nova Scotia nearly $85 million, of which almost $65 million is from the loan for all that land.
As Halifax Examiner readers may recall, Northern Pulp is one of seven affiliates — including Northern Timber — that filed for creditor protection in the BC Supreme Court in June 2020, despite being part of the multi-billion-dollar global corporate empire of the multi-billionaire Widjaja family. (Lots more on that case here, here, here, here, here, not to mention that the company also wants to sue the pants off Nova Scotia, as we reported here.)
According to the July 22, 2020 affidavit submitted to the BC Supreme Court by Duff Montgomerie on behalf of the province, Nova Scotia agreed to a freeze on the repayment of the loans.
Nevertheless, Northern Pulp still owns the land obtained with that unpaid loan, and Atlantic Mining NS says it is “in process of negotiation [sic] surface titles” for the use of the Northern Timber land where the Beaver Dam mine would be located.
Atlantic Mining NS also reports that it has negotiated surface leases for part of the haul road that will be used to transport ore from Beaver Dam to Moose River, and that the “remaining surface rights are currently under negotiations with Northern Timber and applications [sic] crown lease parcels.”
So yes, that means that Atlantic Mining NS is negotiating to lease or to buy Northern Timber land for its Beaver Dam mine project, land that the Northern Pulp affiliate will profit from, even though it still hasn’t paid its debt to the people of Nova Scotia who kindly loaned the company the money to buy the land in the first place.
Just another story Made in Nova Scotia, Canada’s Ocean Playground.
“Impacts on local Mi’kmaq severe”
The proposed mine is close to two Reserves belonging to Millbrook First Nation. One comprises 49.4 hectares (ha) at Beaver Lake, just five kilometers from the mine site. The other is a 32.7-ha Reserve at Sheet Harbour, 20 km south of the planned gold mine.
According to Atlantic Mining NS, the area is:
… an important resource area for Millbrook First Nation community members and by extension, all Mi’kmaq of Nova Scotia and any Project activities may have potential impacts on the ability of the Mi’kmaq of Nova Scotia to access certain areas to practice their rights where species with important cultural relevance may be found. Wild meat was traditionally a staple of the Millbrook First Nation diet, and a few of the harvesters interviewed … indicated they rely mainly on this food source and they share their food with other community members, rather than purchase their meat at a local supermarket.
Some Mi’kmaq community members have camps on Crown land where they go to enjoy peaceful recreational and traditional activities with family and community members. There are five camps documented within 1 km of the Haul Road and multiple other camp locations throughout the LAA [Local Area Assessment].
On June 8 this year, Millbrook First Nation Chief Robert Gloade and 11 Band councillors wrote a letter to James Millard, then Atlantic Gold’s “Manager Mining and Permitting” and now an “independent environmental consultant,” in which they stated Millbrook First Nation’s opposition to the mine.
The letter is powerful and merits being repeated here:
Over the past 6 years, the Atlantic Gold Corporation has been consulting with the Mi’kmaq of Nova Scotia to fulfil the Crown’s duty to consult. Our Community, Millbrook First Nation, has been heavily involved, even taking the lead on the Beaver Dam mine file due to its proximity to Beaver Lake I.R. [Indian Reserve] #17.
Through the consultation process Millbrook has taken the approach of engaging its membership to document concerns and quantify impacts. We have held information sessions, completed a Traditional Land and Resource Use Study (TLRUS) and most recently finalized a Community Consultation Report to gather opinions regarding the company’s proposed mitigations. In addition to the community-level work, we contracted a scientific review of the Environmental Impact Statement (EIS), conducted by Management and Solutions in Environmental Science (MSES). Each of these studies came to the same conclusions – (1) the extent of the impacts on the local Mi’kmaq is severe and (2) our membership does not support the project, because they fear for their health, their livelihoods and their way of life. It is because of the conclusions of these works that we, Millbrook First Nation, do not support the proposed Beaver Dam mine site. [emphasis in the original letter]
We have the fiduciary responsibility to act on behalf of our constituents. They have made it quite clear that they do not want the mine project to be approved and they want Millbrook Chief and Council to voice their opposition. The specific reasons are well documented in the reports noted above and will be further examined in our upcoming Health and Wellness study, which will be conducted as part of the consultation process.
We understand that a great deal of monitoring and modelling work has been completed in preparation of the EIS, but we are not convinced that the mine will not pose major health and environmental issues. We cite the malfunction that occurred during the early stages of Touquoy’s operation, as well as the 32 Provincial environmental charges brought before the Courts this past spring. This shows a poor established track record on behalf of the Proponent. This does not instill any faith in the proposed Beaver Dam mine site.
We also understand that the nature of Crown consultation does not afford a “veto card” to the Indigenous peoples of Canada, however we hope that the Impact Assessment Agency of Canada (IAAC) acknowledges that they have the ability to exercise discretion when it comes to the decision to approve the project. We are making short term decisions with long term consequences. IAAC has been presented with evidence that the Mi’kmaq will bear the brunt of the adversity brought about by the development of an open pit gold mine and its infrastructure.
It is worth noting that the federal government has the dual responsibility of ensuring the safety of the environment by virtue of the IAAC process and the responsibility of ensuring the safety of First Nations by virtue of Indigenous Services Canada (ISC). We are currently in the era of reconciliation, where our nations must strive toward a government-to-government approach to consultation. For this to work, the Mi’kmaq must be heard, and our concerns must be acted on.
In its EIS summary, Atlantic Mining NS goes on at great length about its consultations with First Nations, and also with neighbouring communities, noting that it set up a Community Liaison Committee in 2015, and that Chief and Council of Millbrook and Sipekne’katik First Nations had appointed two members to represent them on that Committee.
Then, as if a mere afterthought, the company notes that both Millbrook and Sipekne’katik First Nations have withdrawn from the Community Liaison Committee.
The Halifax Examiner attempted to speak with Millbrook First Nation Chief Gloade about his community’s opposition to the mine, and will update this article when or if we hear back.
Promises and claims
On October 31, 2021 the Impact Assessment Agency of Canada (IAAC) wrote to Craig Hudson, head of permitting for Atlantic Mining NS to inform him that it had received the company’s latest Environmental Impact Statement for the proposed new gold mine at Beaver Dam, and that the “technical review” would begin on November 16, 2021.
The new documents are posted on the IAAC website, and “the public and Mi’kmaq of Nova Scotia” have 30 days — until December 16 — to comment.
Meanwhile, the Halifax Examiner has been wading through the most recent set of documents that St Barbara submitted to the IAAC and Nova Scotia Environment and Climate Change (NSECC).
It is quite a slog. There is a 194-page EIS summary, countless pages of the revised EIS, which comprises 12 separate documents and 64 appendices, and 1041 pages of “Responses to Information Request, Round 2.”
In addition to the endless list of promises and claims, which would have us all believe an open pit gold mine is a benign little project and that the company will make sure that there are no serious damages caused to human or environmental health, there are also more than a few contradictions in and questions that arise from long-winded EIS submission.
There is also the question of who will monitor to see if all the many promises are kept if the mine gets approval and goes ahead — the company itself?
All should be cause for concern.
Confusing and contradictory numbers
Let’s start with that haul road and how the ore will get from the mine to the processing facility.
Atlantic Mining NS intends to transport ore from the Beaver Dam mine to the Touquoy gold mine at Moose River, where production will be winding down. The company plans to use the existing facilities at Touquoy to continue the cyanide processing of ore from the other three mines it has proposed for the Eastern Shore, and to put the toxic tailings from the processing into the exhausted open pit at Touquoy.
That will mean hauling the ore over public and private roads from all three planned mines — 30.1 km from Beaver Dam, of which 10.7 will be on a public road, 93 km on public road from Fifteen Mile Stream initially, and later 45 km, more than 30 of them on a public road (Highway 224, Moose River Cross Road and the Mooseland Road), and 142 km from the proposed mine at Cochrane Hill, 97 of them on Highway 7, 21 on Highway 224, and then 24 more to Touquoy.
But Atlantic Mining NS doesn’t like to remind regulators at the IAAC and Nova Scotia Environment and Climate Change that all of these mines are in fact linked, part of what was formerly called the “Moose River Consolidated Project.”
Which is why its applications are made one mine at a time.
And for now, the St Barbara subsidiary is focused on Beaver Dam.
In its latest Environmental Impact Statement summary, the company says the road will include four main segments:
- 2 km existing Beaver Dam Mines Road, that extends east from the proposed mine site to highway 224, which will be upgraded to support ore transport and will include bypass road.
- 4 km of new constructed road west of Highway 224 to connect the Haul Road to an existing forestry road, this section will not include bypass road.
- 2 km existing forestry road that extends east to the Mooseland Road, referred to locally as the Dump Road, will be upgraded to support ore transport truck and will include bypass road.
- 10.7 km Mooseland Road that will be upgraded by Department of Transportation and Infrastructure Renewal (TIR) [now Public Works] extends north along the Mooseland Road to the existing Touquoy Mine. Bypass roads crossing and parking area is [sic] currently being considered in the design to address safety concerns by local residents.
Portions of the Haul Road route (approximately 16 km) will be upgraded to a dual lane road to facilitate the safe passage of two-way truck traffic at a maximum speed of 70 kilometres per hour (km/h). By-pass roads to allow light truck traffic and recreational vehicles (e.g., ATV and snowmobiles) to maintain continued access during operations will be constructed adjacent and parallel to portions of the Haul Road.
The EIS summary states that hauling will be done by “highway trucks” 16 hours a day (7am until 11pm), 350 days of the year for the five-year life of the mine. And the ore “will be transported by an average of 95 trucks (e.g., round/return trips or two-way trips) approximately 31 kilometers (km) to the existing and fully permitted Touquoy Mine.”
These numbers don’t match the ones in earlier documents.
In the 2020 “Plain Language Summary” of the Beaver Dam Mine that Atlantic Mining NS provided to First Nations and other communities, it states that “a total of 185 return truck trips per day are planned to transport ore to the Touquoy Mine Site.”
The February 2019 revised EIS sates, “The number of return truck trips per day will be an annual average of approximately 185 (370 one-way trips),” and says the haul road will be “designed to accommodate up to a 68t [tonne] gross vehicle weight in either a B-Train or C-Train configuration year-round.”
If this is the correct figure, it means that there will be a giant truck carrying ore and travelling at 70 km per hour on these gravel roads and crossing Highway 224 about every 2.5 minutes every day from 7 in the morning until 11 at night.
Confounded by the conflicting information about the number of truck trips per day, the Examiner emailed St Barbara spokesperson, Dustin O’Leary, with the following questions:
- Has Atlantic Mining NS reduced the number of average return truck trips between Beaver Dam and Touquoy from 185 (370 one-way trips) to 95 (190 return trips) per day, as is indicated by the discrepancy between the information contained in the 2019 EIS and the 2020 Plain Language Summary, and the latest 2021 EIS?
- If so, why the change? Is less ore being produced?
- If not, will Atlantic Mining NS amend this information in the latest EIS for the IAAC?
This is how O’Leary answered — or rather didn’t answer — the questions:
St Barbara is pleased that the Information Request Round Two submitted to the Impact Assessment Agency of Canada (IAAC) on the proposed Beaver Dam Gold Mine has met conformity and that members of the public now have another opportunity to provide feedback on the project. The recent submission is exhaustive and provides the Company’s best effort to address concerns raising in previous rounds of Information Requests while building a project that responsibly protects our shared environment and employs hundreds of Nova Scotians.
St Barbara looks forward to engaging with rightsholders, stakeholders, community members and regulators to address any additional concerns raised and to ultimately receive approvals for the commencement of operations at Beaver Dam.
The environmental costs of hauling ore
It’s not just such numbers in the Atlantic Mining NS documents submitted to the federal and provincial regulators that are confusing.
It is also not clear whether the trucks carrying ore will or won’t be covered. Recall that arsenic is found in rock throughout the province, and that it is particularly prevalent in historic mining sites, such as Beaver Dam.
Atlantic Mining NS reports elevated levels of naturally occurring arsenic in test pits at the Beaver Dam mine site.
The EIS summary makes it sound as if there will be no covers over the ore in the haul trucks, and that this should pose no problem:
Dust is not expected from uncovered trucks because the ore material is of a size that is unlikely to generate dust.
In contrast, Appendix C.3 (Draft Fugitive Dust Control Plan) says:
There is the potential for dust to be blown from haul trucks that are uncovered. Dust can also be tracked across asphalt roads and re-entrained by traffic or by the wind.
And then the company makes this vague statement about ways that dust from the trucks could be mitigated:
Cover truck loads whenever feasible with durable materials such as tarpaulins or screening material that are extended over the truck bed and secured to the truck.
The “whenever feasible” looks like an escape hatch large enough to drive a haul truck — or a whole fleet of them — through.
In an email, Jim Kuipers, a graduate of the Montana School of Mines and a professional mining engineer with 40 years of global experience, told the Examiner that:
The health risks from fugitive dust are relatively well known, but in most cases not regulated. Dust from ore trucks could cause contamination along the road.
In Kuipers’ view, “It would make sense to push them [Atlantic Mining NS] to cover all trucks using off-site roads.”
And there are other potential environmental costs of all that ore hauling, some quite high.
A simple calculation shows that if there will indeed be 185 return trips a day as stated in the Plain Language Summary (and O’Leary didn’t contradict that), over the planned five years of the mine’s operation, haul trucks will travel nearly 19.5 million km.
That is the equivalent of 25 trips from the earth to the moon and back, or 487 trips around the world.
Assuming the trucks will be run on diesel fuel (there is no mention of any alternative), and an average mileage of 42 litres per 100 km, over the life of the Beaver Dam mine the trucks will burn through 8.2 million litres of fossil fuel, and that in the midst of the climate crisis.
According to Atlantic Mining NS, during the construction and operational phase of the Beaver Dam mine, emissions of greenhouse gases will come from the explosives used in rock blasting, but the “primary source of GHG [greenhouse gas] emissions is diesel fuel use,” from “diesel power generators and haul road trucks.”
But no worries, because Atlantic Mining says it “will take steps” to mitigate these emissions:
… through activities such as reducing engine idling, where possible, and considering the use of more fuel-efficient vehicles and equipment. [emphasis added]
Nor do the documents provide any analysis of the greenhouse gas emissions that will come from the land and forest disturbance, the loss of soil organic carbon and vegetation, and the loss of biodiversity that the mine will cause.
Anyone who has visited the Touquoy mine — or any open pit gold mine anywhere — will know that the land disturbance caused by this kind of mining is as dramatic and extreme as any human-caused land disturbance gets.
Then there is the tax that Atlantic Mining will not have to pay on those millions of litres of fuel.
As the Examiner reported here, in 2017 then Liberal Minister of Transportation and Infrastructure Renewal, Lloyd Hines:
… brought in a new perk for the mining industry in the form of a fuel tax rebate, telling the legislature, “I’ve been very happy to be talking to the senior mining partners in the province who are very grateful, including MANS [Mining Association of Nova Scotia] that this government provided that rebate and corrected that inequity that existed.”
That means that even though the heavy Atlantic Mining NS trucks will be plying and no-doubt potholing public roads as they transport the ore, they will be doing so using tax-free fuel, unlike the rest of us. Just about every dollar that Nova Scotians pay on the fuel they use in their personal vehicles is invested in roads.
Speaking of taxes …
Throughout its latest EIS summary Atlantic Mining NS boasts repeatedly about how much purported wealth it will be bringing to Nova Scotia and Canada, making these claims over and over again.
Here is what it states on page 23:
Tax revenue in the millions of dollars per year will be generated through corporate income taxes paid by the Proponent, as well as its contractors and suppliers.
And page 152:
Tax revenues and royalties will be generated by the Project that will benefit all levels of government: federal, provincial and municipal.
And in case you missed either of those, here it is again on page 153:
Tax revenue in the millions of dollars per year will be generated through corporate income taxes paid by AMNS, as well as its contractors and suppliers.
And again on page 153:
All phases of the Project will provide employment opportunities for local residents and Indigenous Peoples, as well as provide tax revenue for the municipal, provincial, and federal levels of government.
And then once more on page 154:
Positive impacts are anticipated in the form of direct and indirect employment, and tax revenues for municipal, provincial, and federal governments.
And for the sixth time, here is the claim again on page 196:
Tax revenue in the millions of dollars per year will be generated through corporate income taxes paid by AMNS, as well as its contractors and suppliers.
As the Examiner reported here, the annual reports that Atlantic Gold (or its subsidiary Atlantic Mining NS that operates the Moose River mine) submits to Natural Resources Canada under the Extractive Sector Transparency Measures Act, or ESTMA, show that the company paid $0 in taxes to the federal or provincial governments in 2017, 2018, 2019, and also 2020.
From that 2021 Examiner article:
Since it produced its first gold bar in October 2017, the Moose River mine has produced close to half a billion dollars worth of gold: 90,531 ounces worth nearly $150 million in 2018; 93,000 ounces in 2019 worth more than $170 million; and 107,000 ounces in 2020 worth close to $254 million.
Even when the “all-in sustaining cost” per ounce of gold produced is deducted for each of those three years, the company’s net take was well over $350 million.
Fact is that the only provincial and federal taxes generated by the Touquoy open pit gold mine are coming off the paycheques of employees and contractors.
At this point there is no reason to believe that if the Beaver Dam mine goes ahead, St Barbara or its Canadian subsidiary (or subsidiaries — the company doesn’t make public its corporate structure so we don’t even know if Atlantic Gold still exists) are suddenly going to start paying “millions of dollars” of “corporate” taxes to either the government of Nova Scotia or of Canada.
Keeping an eye on the comments
So what happens if a corporation provides misleading or false information to the Impact Assessment Agency of Canada?
The Examiner asked the IAAC that very question and received this reply:
Comments received by either the Agency or the Nova Scotia Department of Environment and Climate Change by December 16, 2021 will be considered, including those previously submitted.
If a comment received identifies potential errors in the revised EIS, the Agency will validate the content of the EIS with federal and provincial technical experts and determine if additional information is required from the proponent.
Comments are rapidly piling up on the IAAC website, and it remains to be seen what the public and Mi’kmaq of Nova Scotia will identify as concerns in the thousands of pages that Atlantic Mining NS submitted for its Beaver Dam project.
One thing is clear: St Barbara has a lot riding on the outcome of the Beaver Dam assessment.
Production has been dropping at the Touquoy mine that is scheduled to wind down gold production next year, and the company has been relying on — and telling investors that it will have — uninterrupted gold production at the three satellite mines along the Eastern Shore.
St Barbara has another open pit gold mine in Papua New Guinea, but it suspended operations following the death in June 2021 of a truck driver at the mine and a failing deep sea tailings pipe.
St Barbara also operates a gold mine at home in Australia, but production has not been stellar there.
So the company is depending heavily on what it calls its “Atlantic Operations,” and right now, those depend almost entirely on Beaver Dam getting the green light from IAAC and NSECC.
And if the comments on the IAAC website are any indication, it looks as if St Barbara has been hoping that its employees can help convince regulators in Canada to approve the project.
On November 24 alone, there were 12 almost identical comments from “team” members of “St Barbara’s Atlantic Operations” each claiming, “I have taken the time to review items submitted to the government, in supporting this project [sic], please accept my following comments as a part of the consultation on the Beaver Dam Mine Project,” and then regurgitating the same text about how the “project can be completed safely, while protecting our shared environment and is something that all Nova Scotians can take pride in.”
But not “all Nova Scotians” think this mine is anything to “take pride in.” As of this writing, there are 23 comments on the latest proposal from people strongly opposed to the mine, all offering individual explanations of why. This comment from Bradley Gaetz, for example:
What parts of the hundreds of devastating scientific reports on wildlife decimation, species depletion and looming climate change disaster do government and business proponents of these vast, open pit gold mines not get? The few, dead end jobs created and illusional royalties, never seen after tax and capital investment writedown manipulation, don’t even come close to a creating justification for the dystopian moon scrapes left behind by foreign mining interests. For what other purpose? Human vanity and hubris.
For her thoughts on the latest Atlantic Mining NS documents, the Examiner contacted Barbara Markovits of the Eastern Shore Forest Watch Association, which has been opposing gold mining in the area since before the original proponent, the Australian company with a Vancouver office, D.D.V. Gold, first got approval for the Touquoy mine from then Nova Scotia Environment Minister, Mark Parent, in February 2008.
Said Markovits about the latest AMNS submissions to the IAAC and Nova Scotia Environment and Climate Change:
Here at Forest Watch we are concerned about the company’s responses to information requests, but we’re even more concerned about the huge toxic impact on the entire Eastern Shore over a period of years. So we are now pushing a counter-narrative to Atlantic Gold’s “four-small-gold-mines-we-won’t-bother-anyone,” the counter-narrative being “One Enormous Negative Project That Affects Our Water, Our Wildlife, Our Lives.”
 Atlantic Mining NS is due in provincial court on Monday, November 29, 2021 on 32 environmental charges laid by the provincial government, and three additional ones laid by the federal government. It will be the eighth time the company has appeared in court without entering a plea on the environmental charges. Although the company tentatively agreed to a plea deal to pay $120,000 to the Nova Scotia Salmon Association, the NSSA told the Examiner that they would not accept the deal.
 According to a provincial – federal 2019 Memorandum of Understanding on interprovincial operations of heavy trucks, B- and C-train double trailers can have from five to eight axles. B-train doubles can have weights of 40.7 to 62.5 tonnes, and C-trains of 41.9 to 58.5 tonnes.
 If there are 370 single trips per day, this means the haul trucks will travel 11,137 km each day, and 3,897,950 km each year (350 days a year according to AMNS). Over the 5-year lifetime of the mine the trucks will thus travel 19,489,750 km.
 The calculation of average diesel consumption is made using figures on this website, which states that “larger trucks can typically use between 35 and 50 Litres of diesel per ever [sic] 100 kilometers. Large trucks that are used for commercial hauling, usually use the largest amount of fuel per kilometer.” For the estimate of how much fuel the trucks would use hauling ore between Beaver Dam and Touquoy, the Examiner calculated using a mid-range figure of 42 litres per 100 km.