Concerns with the Great Bear Resources Gold Project

As a resident of northern Ontario, I have too often experienced and seen the harmful effects of gold mining in our home. I have several concerns with the impact statement that I would like to highlight. 

In section 3.4 of the document, the company states that they gave presentations to Lac Seul First Nation, Asubpeeschoseewagong Netum Anishnabek, Waubaskang First Nation, and the Northwestern Ontario Metis Community about "potential health effects to Indigenous people" and hosted workshops related to "fish habitat offsetting, Species at Risk, mine closure scenarios, and effects assessment". In presentations to Government Agencies, the company shared presentations on "migratory birds, water management, aquatic effects and fish and fish habitat offset measures, and also included methylmercury bioaccumulation modelling in fish and consumption of fish by Indigenous people.

I have concerns about whether the information shared with government agencies was the same information that was shared with Indigenous communities. While the company engaged in Traditional Use and Knowledge consultation with communities, where concerns including health of fish, methyl-mercury contamination, and water protection were raised, they do not include the details about whether these topics (that were presented to government agencies) were shared in detail with the affected communities.

The maps in Section 5 do not show the position of the mine in relation to the larger watershed of the region. The maps are not detailed enough to see how the tailings facility(ies) may impact the surrounding waterways, and is not detailed enough to give communities a sense of areas that could be affected. The tailings pond is alarmingly close to the shore of Gull Rock Lake. How will the company adequately manage tailings within 2 km of such a large water body? How will they ensure no groundwater leaching occurs during operations and "remediation"? These maps also do not show sensitive riparian areas or wetlands, or other special environments.

In Section 6.4 (Changes to Groundwater Quantity), the company states that "grouting" will be used to seal exploration holes and pressure cracks. What substance is the grouting made of any how long is it expected to last in the environment? 

In Section 6.6 (Changes to Groundwater Quality), the company states that regular effluent discharges of dangerous and toxic materials will occur into surrounding freshwater. Though they are predicted to "meet [governmental] regulatory requirements", errors can and do occur. I expect that there are fines related to breaking these regulatory requirements, but the environmental damage cannot be remediated with money alone. 

In section 6.10 and 6.11(Changes to Other Wildlife and Changes to Species at Risk), the company states that "Direct losses of other wildlife habitats will occur within the PA during construction, but no critical habitat types are eliminated at the regional scale." The regional scale is not a reasonable metric for Indigenous communities who rely on traditional knowledge and lived experience for subsitience hunting or protection of local animal communities.

In section 7.3 (Changes to Indigenous People), the company states that the "residual effects" of the operation will be non-significant or that a determination is not required. However, there is a mitigation measure listed for nearly every potential impact to Indigenous people. Despite anyone's best intentions, these mitigation efforts will not be completed perfectly, and there is a high likelihood of massive damages to Indigenous people's land use, culture, access to resources, or archaeological/spiritual sites simply due to the nature of mining. It is untrue to classify these residual effects as non significant when the company is well aware of the likelihood of failure or non-compliance in mitigation efforts.

In section 8 (Potential for Cumulative Impacts), the company once again states that residual effects will be none or non-significant "after mitigation efforts". Once again, I would like the company to report upon the efficacy of each of the proposed mitigation efforts in their other projects to support their claims of no or non-significant residual effects (see comment on section 7.3).

Importantly, there is no section summarizing the company's plan for remediation. We have seen time and time again in Canada companies declaring bankruptcy to avoid environmental clean up. The company makes no mention of commitment to the Ontario Mine Rehabilitation code, nor do they provide details on how they plan to decommission the mine site and surrounding effects. This exemplifies that the company is irresponsible and unprepared for the scale of environmental disruption and destruction that this project will create. I do not support further mining development in this region. I do not believe that the paltry 26-year lifespan of this mine and the financial gains made by this project will provide any meaningful, generational benefit to the people of Northwestern Ontario.