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Comments submitted to the Canadian Environmental Assessment Agency (CEAA) Regarding the Comprehensive Study of the Aquarius Mine

May 2, 2000

Marie-France Therrien, Senior Analyst
Canadian Environmental Assessment Agency
200 Sacré-Coeur Blvd., 13th Floor
Hull, QC KlA 0H3
Tel: (819) 953-2537
FAX: (819) 997-4931
E-mail: marie-france.therrien@ceaa.gc.ca

Re: Environmental Assessment, Aquarius Mine Project, Timmins

I am writing on behalf of the Board and members of MiningWatch Canada to express our serious concerns about the Aquarius Mine Project envisaged by Echo Bay Mines.

  1. There has not been adequate opportunity for the affected public to intervene on this project. We understand that the project name and district were posted incorrectly when CEAA first posted the review to the site, and that the appropriate contact information for the Department of Fisheries was not available. Although Northwatch began to try to get a copy of the CSR document list and documents in August, they had still not been received at the beginning of March.
  2. Although there were three open houses a few years ago, the local people were not aware that they were consultations as part of the CEAA process, and most of the community thought it was a community relations exercise by the company. As a result, few attended, although there is considerable concern in the local community and from environmental organizations across the province and the country. There are ten residences within 1 km of the proposed operation, who will be considerably affected by it.
  3. The esker system in which this mine will be built is host to the Fredrick House aquifer, a prominent regional aquifer, making the careful management of ground water of crucial importance, and the exercise of the precautionary principle essential. However, this mine relies on the unproven technology of a freeze wall to protect groundwater. We are not satisfied that the full environmental effects of the freeze wall have been examined. Although the technology has been used in construction, we are not aware of its use over time in mining. We are not satisfied that the freeze wall technology will work efficiently. Neither are we satisfied that sufficient backup plans are in place should the freeze wall leak or fail.
  4. The footprint of this mine is large. The perimeter of the pit itself will be 3,500 metres. It will generate 55 million tonnes of overburden and 18.9 million tonnes of waste rock. The stockpile will cover 250 hectares with an elevation of 30 metres. Located 3 km southeast of the mill will be a tailings basin of no less than 50 hectares and a polishing pond of 10 hectares. In addition, the infrastructure will include the mill building, several outbuildings, open pit de-watering wells, tailings and waterlines, a 4 km access road, a 9km powerline, a fuel depot, and on-site non-hazardous landfill, two refrigeration plants and site drainage works. This is estimated to cover another 6-7 hectares. The ecology of the area is already damaged and fragile by the number of mines, mills and smelters in the region.
  5. The increased traffic on Highways 101 and 67 has not been assessed for environmental and social impacts. Transport of cyanide and other toxic materials will presumably be along this route, and the safety of this method of transport needs to be adequately evaluated.
  6. The value of this mine to the local economy over the long-term has not been proven. Although it will provide some much-needed short-term jobs, the damage to the sport fishing and tourism industry in the long term will not be offset. Gold mining is a tenuous industry these days. If we are going to contribute to the development of sustainable economies, we would be wise to question gold as that investment. Gold is increasingly under scrutiny as a feasible driver for the economy. Writes John Young in The Gold Report, "Central banks and international financial institutions hold more than 34,000 tons of gold. This is more than 13 times the annual production of the world's mines; if sold these reserves could satisfy gold demand for more than 8 years (current demand is approximately 4,000 tons per year). Of this demand, 85% is typically used for jewelry." Young argues that the gold is slowly being converted from precious metal to base metal, and that it has been steadily losing value for decades.

This project should not go ahead. It has not had proper public consultation and review. It represents too great a potential cost to the environment on the area.

Yours truly,

Joan Kuyek
National Co-ordinator