SuNNS Comments on Fifteen Mile Stream

Reference Number



Sustainable Northern Nova Scotia (SuNNS) is responding to the invitation by The Impact Assessment Agency of Canada for public comment on the potential environmental effects of the proposal by Atlantic Gold for the “…construction, operation, decommissioning and reclamation of an open-pit gold mine located approximately 95 kilometres northeast of Halifax, Nova Scotia. As proposed, the Fifteen Mile Stream Gold Project would include open pits, stockpiles, materials storage, crushing and concentrator facilities, water management and treatment infrastructure, mine haul roads, and an above-ground tailings management facility. Ore would be crushed and concentrated on site to produce a gold concentrate that would be hauled to Touquoy Mine for final processing, a distance of 76 kilometres on existing public roads.”


SuNNS is a group of concerned citizens on the North Shore of Nova Scotia committed to sustainable, locally driven community and economic development. The society formed in 2018 in response to a proposal by the Department of Natural Resources to solicit exploration for gold in the French River Watershed, the sole drinking water source for the village of Tatamagouche. 

SuNNS would raise the following concerns with respect to the proposed Fifteen Mile Stream Gold Project. 

  1. Incomplete Scope of the Environmental Impact Assessment

The proposed Fifteen Mile Stream Gold Project is not a stand alone project and should not be assessed as such. 

The 250 hectare open pit mine is one piece of a much larger project, Atlantic Gold’s Moose River Consolidated Project,  which includes mining sites at Moose River (Touquoy Mine), as well as proposed sites at Beaver Dam and Cochrane Hill in addition to Fifteen Mile Stream. These four sites extend some 114 kilometres and are part of a larger integrated mining, ore processing and waste management whole. 

Atlantic Gold’s proposal is to excavate large open pit mines at each of these sites, carry out preliminary crushing on site and then truck the more concentrated ore from Fifteen Miles Stream, Beaver Dam and Cochrane Hill to the Moose River site for final gold extraction with cyanide, where effluent will run into a 3.5 kilometre long tailings pond held by a rock and clay wall. 

In the case of Fifteen Mile Stream, ore will be trucked  75 kilometres over public highways, including Highway 7. 

Fifteen Mile Stream is also part of larger geographical watersheds. Effluent from the Fifteen Mile Stream empties into the East River and eventually will empty into Sheet Harbour.

The true environmental impact of the proposed Fifteen Mile Stream project can only be calculated if it is not siloed from the environmental impact of the processing of ore to be done at the Touquoy Mine in Moose River and the environmental impacts of the other two proposed mining pits. 

In other words, the environmental assessment of the Fifteen Mile Stream proposal must include all elements of the Moose River Consolidated Project. There is ONE project, not four separate unrelated projects, and it is taking place in one geographic area of Nova Scotia. 

2. Environmental Record of the Proponent

Atlantic Gold currently faces 32 charges under the province's Environment Act related to its gold mining operation in eastern Nova Scotia. The company is charged for 19 times "failing to comply with the conditions of an approval" and 13 counts of "releasing substances into the environment in amount, concentration or level in excess of approval level or regulation” between February 2018 and May 2020. The infractions occurred in the areas of Moose River, 15 Mile Stream, Jed Lake and Seloam Brook.

A rough “back of the envelope” calculation shows that Atlantic Gold was failing to meet environmental standards and its conditions of approval once a month on average from February 18, 2018 through to May, 2020. 

One charge involved the leaking of 380,000 litres of contaminant-laced slurry at the Moose River mine on January 3, 2019, the contaminant being arsenic. The company says the spill was contained, but the charges have yet to be heard in court. 

Such mining failures underscore the known high risks that are part and parcel of mining for gold. 

There is a particular irony that Atlantic Gold is already facing charges under the Environment Act related to Fifteen Mile Stream while offering assurances that it will prevent or mitigate future environmental damages there.  

SuNNS believes that the record of failure of Atlantic Gold to meet environmental and operating conditions to date should disqualify this project proposal. 


3. Failure to Meet Terms and Conditions


When the predecessor to Atlantic Gold (DDV Gold) received its environmental approval at Moose River in 2008, the approval came with Terms and Conditions including that within four years of the date of the approval, the proponent would develop and implement a plan for procuring 256 acres of conservation land with high biodiversity value to be handed over to the province (presumably as compensation for the environmental destruction of the gold mine). 


To date, Atlantic Gold has not complied with this condition of its environmental approval.


Again, this goes to the failure of the project proponent to meet conditions and terms set by the regulator. How can the proponent guarantee that it will act differently now than previously? 



4. Unsubstantiated Royalty Projections 


Atlantic Gold’s projection of corporate income tax royalties in the amount of $9.9m (provincial) and $7.2ml (federal) per average operating year are not substantiated.


These projections differ substantially from the actual history of royalties paid to provincial and federal governments to date. 


In 2017, Atlantic Gold paid nothing in taxes in royalties to any level of government, according to the report it filed under the Extractive Sector Transparency Measures Act (ESTMA). 


In 2018, Atlantic Gold paid zero dollars in taxes to any level of government, and just $1.18 million in royalties to the province.


In 2019, Atlantic Mining NS paid zero dollars in taxes to any level of government and just $1.33 million to the province of Nova Scotia. 


This was despite record years of production, according to the company, and record prices for gold. 


While SuNNS does not agree with the implied trade-offs in the environmental impact assessment of “economic benefits” versus “the environment”, if the calculations are to be done, the projections of economic benefits of the Fifteen Mile Stream project to municipal, provincial and federal governments must be dismissed as not credible.


5. Tailings and Waste


Atlantic Gold is asking to be allowed to generate 13.4 Mt of tailings and 24.4 Mt of waste rock from the Fifteen Mile Stream mine in what they term to be a “remote” area of central Nova Scotia. 


This will be situated within the Liscomb Game Sanctuary. 


Atlantic Gold is proposing construction of a conventional slurry tailings facility with a footprint of 142.8 ha, impacting  12.1 ha of wetland and 12.1 ha of mainland moose habitat. The tailings dam height will be 32 metres and the tailings dam length will be 3.1 km. 


During the last decade, tailings spills have damaged 2,100 kilometres of waterways, claimed 482 lives and, with 71 known failures and more than 100-billion litres of mine waste has been spilled. 


What financial sureties do the federal and provincial government have to ensure from Atlantic Gold that they are prepared to cover the costs of these potential claims?


6. Nova Scotia’s Liabilities from the First Gold Rush 


Nova Scotia’s Auditor General has drawn attention to the province’s financial liabilities for remediation of 69 abandoned gold and coal mine sites on Crown Land that go back to the 1800s. 


The province previously announced it estimates the cost of cleaning up Montague Gold Mines and the Goldenville mine site, near Sherbrooke on the Eastern Shore, will be about $48 million.


But there are more than 60 other former gold mine sites on Crown land that are also on the province's list to be cleaned up.


As the AG reported in July 2020, Nova Scotia does not have a good grasp on assessing or managing or monitoring contaminated sites despite the risk they pose to human health and the environment. 


What steps has the government of Nova Scotia taken to address these concerns? 


7. Long Term Monitoring


Following the disastrous gold mine tailings failure in 2014 at Mount Polley, B.C., the provincial auditor general, Carol Bellringer, commissioned a full assessment. One of the concluding statements in her report was that “these (mines) are going to require lifetime water treatment and monitoring.”  Following this report, a Toronto-based gold mining company, Seabridge Gold, in their application to open a gold mine in B.C., stated that they are prepared to treat runoff from piled waste rock in B.C. for 200 years.


How long is Atlantic Gold prepared to treat runoff from this mine? What sureties do the province of Nova Scotia and the federal government have in place to ensure this is a realistic commitment? 



In conclusion, SuNNS does not believe that the proposal from Atlantic Gold passes an environmental assessment or contributes in a meaningful way to the economic, cultural or environmental well-being of Nova Scotia. 


For these reasons, SuNNS urges the federal and provincial governments to deny the application of Atlantic Gold  to proceed with this project. 

Submitted by
Sustainable Northern Nova Scotia (SuNNS)
Public Notice
Date Submitted
2021-04-30 - 7:16 AM
Date modified: