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On June 1, 2005, Pioneer Coal submitted an Environmental Assessment Registration Document for a proposed strip mine near the Prince Mine Site in the Point Aconi Resource Block. Over a 7 year period, 1.6 million tons of coal will be extracted. The deadline for public comment on the registration document is June 16, 2005. Please read the necessary documents and use the guidelines below to enter your comments about this project on the government Web site.
Enter your comments by June 16, and help stop the rape of another part of Cape Breton!

Preliminary comments about the Pioneer Coal Ltd.
Environmental Assessment Registration Document (EARD):

The most effective argument opposing this EARD are those that demonstrate that the document is incomplete, poorly done or contains false or misleading information. Specific reference to information in the document is also beneficial. The Pioneer Coal Ltd. Environmental Registration Document is available at the following address: www.gov.ns.ca/enla/ess/ea/princemine.asp. You can also enter your comments directly from this Web site.

A key to discrediting this report is that there was no original research conducted on the part of the proponent (info used by Pioneer is dated), yet, sweeping conclusions are made about the effect this project will have on the environment.

Not only has the proponent not conducted any new or original research, but it is indicated that only after they are granted an approval for the Environmental Assessment that they will do the research and develop the necessary strategies to deal with negative issues surrounding the proposed open pit mine. This is not the way the process works.

All of these issues must be addressed up front so that the public has the opportunity to assess the true impact of the proponents project. For instance, Section 3.2.6, Contingency Planning, the proponent states that "contingency plans for the proposed undertaking will be submitted as part of the IA application". Similarly, section 7.2 suggesting there "will be" contingency and emergency planning. This is unacceptable. How can the public assess the viability of such contingency and emergency plans if they have not submitted them? Such components of a registration document are not done after the fact as the purpose is to demonstrate transparency on the part of the proponent so the public has an opportunity to evaluate all aspects of the proposal.

Pioneer Coal Ltd. indicates in Section 2.6 that "Environmental management is a priority to Pioneer Coal", yet, the proponent does not take any initiative in assessing what should be considered to ensure proper environmental management with regard to its proposal as it has conducted no original analysis in any aspect of this report.

Emphasize that Pioneer Coal makes sweeping proclamations that no significant impacts will occur on groundwater, surface water, fish habitat but no research was conducted to determine if these statements are true.

Arguments you can use to Oppose the Pioneer Coal Ltd.
Environmental Assessment Registration Document (EARD):

Please feel free to cut-and-paste the arguments below
into the Comments Section of the government Web site

Strip Mining Study - The Department of Environment and Labour is presently conducting research and will issue a report on the cumulative effects of coal mining in Cape Breton including areas spanning Glace Bay to Point Aconi. The EARD proposed by Pioneer Coal Ltd. is jumping the gun with regard to this DEL report. The DEL should conclude its study and produce its results before allowing Pioneer Coal Ltd. EARD to pass.

Fishing Industry - With regard to the fishing industry in the proposed area this EARD provides a very poor assessment of the potential effects of the proposed mine on the local fishery with no original research reported. There is little mention of the fishery throughout the EARD.

  • A) Section 4.6.2 of the report indicates that information about the fishing industry comes solely from data collect from the NSPI EAR in the year 1989, a full 16 years out of date. As well, it is even noted that "no additional marine studies were undertaken" to assess the effects of this mine on the fishery.
  • B) While barely mentioning the fishery as a whole it pays even less attention to the lobster and crab fishery stating only that lobster and crab are common in the area. It is later concluded in Section 6.5.2.4 "that no cumulative effects on the fisheries are expected"
  • C) There is no mention of the effects of the mine nor the waste pile that will come within a few meters of the ocean (i.e. runoff, increased sedimentation, etc)

Pioneer Coal Ltd. has used outdated information and provides no evidence that would back up their claims that there would be "no cumulative effects on fisheries" as stated in Section 6.5.2.3

Drawdown on Water Wells - Again, no new research was conducted. The report with respect to drawdown relies on previous studies which showed roughly a 3 metre drawdown on domestic wells within and area ranging over half a kilometer based on the "data sources indicate effects from former mine operations, which included excavations up to 20-25 metres below ground surface…these effects from past operations were recorded to be a maximum of 3 metres, which is not considered to be problematic for most drilled domestic wells in the area" However, the purposed undertaking indicates excavations be up to 50 metres deep as indicated in section 3.3.3, twice the depth.

Bird Islands - The effects of the mine and its operations on the Bird Islands is not accounted for, which is surprising since this region is the closest point of land to the Bird Islands. The report mentions that birds use the shore line around Boularderie Island, but it doesn't assess the importance of the shoreline, which species use the shoreline, when etc. Again, no new research was done.

Mi'kmaq god Klusap and Kelly's Mountain - There is no mention of the importance of Kluscap to the Mi'kmaq people and how the open pit mine will damage this sacred ground. Kelly's Mountain is considered the abode of Kluscap, a very important figure to the Mi'kmaq people, and the point of his prophesized return. The open pit mine will be visible from the sacred land and yet the proximity of this mine is not even mentioned in the report.

Tourism - Section 6.5.4.9 notes that "current aesthetics of the Prince Mine site are not positive", but there is no mention of the increased aesthetic damage to the gateway of the Bras d'Or Lakes as a result of the open pit mine. In fact, the report indicates that there will be positive benefits in the long run with reclamation, but what about the seven years worth operation? Given the increasing importance of the tourism industry in this area (cruise ships, whale watching, etc) it is unbelievable that the socio-economic analysis, which again contains no new or original research, does not address tourism values to the area. The only point of entry to these Bras d'Or lakes is long Boulanderie Island and therefore should have been a priority concern address in the report.

Socio-economic effects of removing the community in Point Aconi - These socio-economic effects are not even addressed beyond issues of acquisition. This project proposed to remove roughly 12 of 30 homes in the Point Aconi region or 50%, yet, issues of loss of heritage, community displacement etc. are not even addressed.

Flora-Fauna - All the surveys indicated in the report rely on existing data which is dated over ten years and no original research was carried out for this report including that of rare and endangered species. How can assessments of the effects on flora and fauna in the region be assessed if there was no new, on the ground research conducted in the area in the last ten years?

Revised: 06/22/05 21:42:56 -0300.