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Comments presented to N.S. Environmental Assessment Branch
RE: Pioneer's Surface Coal Mining and Reclamation Project

Citizens Against Strip Mining
June 13, 2005

Environmental Assessment Branch
Nova Scotia Environment & Labour
P.O. Box 697
Halifax, NS, B3J 2T8


Dear Sir/Madam,

The following is a submission of our concerns, personal, economical and ecological, in connection with the Surface Coal Mining and Reclamation Project registered for environmental assessment by Pioneer Coal Limited on January 01, 2005, with your Department. The location being the Prince Mine site in Point Aconi. As to the site itself, we can agree that it should be reclaimed, be it for economical or aesthetical reasons or simply because it poses a danger to peopleıs health and welfare. As to the manner in which the site is to be reclaimed, we have a number of concerns. For starters, we believe any further attempt to extract coal as a means to reclaim the site would not be in our best interests. Not being experts in means of reclaiming mining sites, we do have a past experience from previous so called ³reclaimed² strip mining sites. That part of the proposal, we presume, would be discussed openly and fully with the participation of the citizens of the area.

Pertaining to the extraction of 1.6 million tons of coal as an ³added on² project simply because the coal is there is of great concern to us as a community.

We want to draw your attention to the fact that this project happens to be located in an area where people live and work, and also that a study carried out a number of years ago had rejected the development of surface mining. The reason was the water. The water table is limited. Boularderie Island is a small island surrounded by ocean water and its potable water is very limited. The Point Aconi Plant already puts a heavy demand on it and it is reasonable to perceive that surface mining would add to the drain of the water table.

This would have heavy consequences on the way people make a living since much of the employment relies on water dependant industries: farming and fishing. Farmers are very aware of the circumstances around the water supply and use it wisely but they cannot afford to have their source of irrigation reduced any further. This would lead to a catastrophy and to the closing of farms.

Fishermen have already been affected by the presence of the Point Aconi Plant which releases warmer waters in the ocean in that area and they cannot afford to see any more strip mining interference with the coastal water. Previous strip mining operations have already resulted in a reduction along the coast line of their fishing grounds.

Though land owners can refuse to see their own land strip mined, they will not be able to control their neighbours if they so wish to accept monetary compensation for the use of their land for the extraction of coal. Strip mining is too large an operation not to be affecting neighbouring lands, as we have already had ample examples of this phenomenon. Also farmers do lease land from absentee owners. If these owners decide it may be more to their advantage to let their land be mined, farmers may be left with a shortage of acreage to lease for present and future farming development in order to meet the demands of increasing population.

We know that, once the top soil and flora have been removed, it will not recover. Arable land takes hundreds of years in order to recover to its previous pristine condition. Here is a rich area of flora that is providing food and shelter for many species of animals on land and sea, and we donıt think it should be allowed to be destroyed since it is irreplaceable and will jeopardize future generations of wildlife habitat, i.e. salmon, lobster, ducks, seabirds, eagles, etc.

So from a sustainable economic point of view, this project is a very precarious and dangerous one. It would exclude any other form of development. Strip mining will not employ many workers because it is very mechanized and for a few workers employed in the mining project, for a very few years, we will be losing hundreds of jobs which would last generation after generation. Short duration and low labour intensity are both anti-economy. Is this reasonable? We donıt think so. The way we see it, it does not make sense economically or ecologically.

Not only the quantity of water would suffer, but also the quality. Wells would sure be affected and many homes would lose their water supply. This project is far too close to sensitive populated areas. Also the quality of the water would be affected: the coal in this area has a high sulfur content which produces sulfuric acid when it comes into contact with air or water. This would poison water courses and water supplies, as well as the waters along the coast nearby which is heavily fished. Run off could include heavy metals such as mercury, arsenic, aluminum, lead, cadmium and zinc. We donıt need this in our fish, crab, lobster to further poison the population. Marine life would suffer and we can assume that if the word is around to our buyers of fish abroad that there is such a danger in buying fish from Cape Breton, all of Nova Scotia will be out of bounds for buyers on the international scene.

If there is ever an argument in favour of sustainable development, allowing strip mining to take place in the area proposed by Pioneer Coal Limited would fly right in its face.

Tourism: this is another major area of concern. Tourism is a major source of revenue in Cape Breton and, as we were warned in a National Geographic study of the best places to visit in the world in which we took second place, we run the risk of losing it all if we mismanage our assets. The proposed strip mining will have the same effect as deforestation and will severely affect the pristine natural circumstances in Cape Breton. Keep cutting, digging, spraying and the very essence of what makes Cape Breton an attractive destination will be lost. This would be another major economical drawback and would not only stall, but reverse, the slowly progressing touristic gains we have had. Tourism has been recognized by the pundits, including the government of Nova Scotia, as one if not the key to economic development. To destroy and deface the very essence of what tourists will more and more be looking for in a world gradually being destroyed, to kill the natural and pristine environment, the beauty, the peace, the spiritually replenishing of our souls, the air, the waters now still relatively free of pollution would be a crime. The proposed strip mining threatens all of thiese and, instead of creating jobs for a very limited future, would kill jobs for many or even all generations to come. We cannot sacrifice the future of generations for the sake of a few dollars earned today. We cannot sacrifice the future for the sake of a few dollars. We must ³invest² not ³cash² our patrimony.

In the governmentıs ³A citizenıs guide to Environment assessment², we read: ³These developments (such as those proposed here) should not compromise our environment, local economy or our communities². We are asking you to apply the principles you yourselves delineated and to give your most serious attention to a great number of citizens as opposed to the wish, satisfaction and profit of a few.

We consider that this project will be very detrimental to our community and will have intense adverse effect on it if we go by Nova Scotiaıs definition of ³Adverse Effect² in again ³A Citizenıs Guide to Environmental Assessment²: an effect that impairs or damages the environment, including an adverse effect respecting the health of humans or the reasonable enjoyment of life or property².

Now, on top of basic needs that would obviously be adversely affected by the above project, there are many others and we will only cite the most evident. One again is a matter of economy, and that is the destruction of properties which are valuable and considered as very desirable. After a great number of years of people paying their property taxes, the assessment of which has been sky rocketing for the last fifteen or twenty years, properties will suddenly drastically drop in value. Even if a property owner refuses to have his land turned upside down, what if the neighbours accept it? Lands which have been strip mined cannot be built on for a great number of years, generations maybe, because the soil sinks and is not stable enough to support a building, whether it be a single dwelling, farm or commercial structure. So the present owner has lost his investment and it closes the door to future potential taxpayers for generations to come. Not only is it not fair to the land owner who loses tens of thousands of dollars in investment, but it deprives the community of future profits by way of taxes paid not only on land but eventually on built up area, as in the case in certain areas targeted in the strip mining projects lined up.

More hardships that would be created by such a project as the one proposed by Pioneer Coal Limited is the noise that would be affecting the population on account of heavy machinery and trucks constantly travelling on roads that are already in a very great need of reconstruction since they have been so neglected for the last ten years and are now already in a state of dereliction. It would be hard on the roads, and the dust from the site as well as from the transport of coal would be affecting the air in a most negative way. The safety of the roads, especially for our children and school buses travelling on the same roads, would be compromised.

For all the above reasons, this project, without any ifs, ands or buts, should require a Class 2 Environmental Assessment. We, as citizens, accept no other alternative than a Class 2 Assessment because of the extremely sensitive and important environmental, economical and ecological concerns previously mentioned. Minister Morash should seriously consider revisiting the environmental criteria for this project.

Unfortunately we have just learned that the present Conservative government of Premier Hamm has given Coastal Construction an exploration permit to extract 5 000 tons of coal. This is completely irresponsible on the part of government to issue such a license when there has been ample exploratory research previously covering the entire coal field in that particular lease. The provincial rules, which we read in your own User Guide to the ³One Window Process for Mine Development approvals and which reads as follows: ³An exploration Licence grants the right to search and prospect for minerals within a designated area. Activities can include prospecting and geological survey work, drilling and minor excavation work LESS THAN 1 METER IN DEPTH AND WITHOUT MECHANIZED EQUIPMENT² . All this having already been done in the recent past, there is absolutely no reason to issue such a permit which is more an authorization for the proponent to make money than to explore. We do not think such a permit should have been issued, nor the proponent encouraged to invest money in a project when no environmental assessment has yet been done and when the first environmental assessment, to be carried by Jacques Whitford and Associates, is not due till the end of August. And when the most legal of all obligations: a a public meeting, has not taken place. We do want you to be aware that, to this date, and in spite of the giving the go ahead to the project behind closed doors, the public has not been informed, let alone consulted, as dictated by the law, and that no public meeting has taken place. We urge you to request a call for a public meeting in the near future. This is long overdue.

In closing, we strongly draw your attention to the last paragraph of the Pioneer Coal Limited ³Notice² that informs the public that all submissions received ³will be made available for public review in the Nova Scotia Environment and Labour Library². This is in Halifax and we donıt think it is at all fair. We ask from you that you make sure that all submissions are also accessible locally, in Cape Breton, in the very area where the publicıs life would be affected. I am sure you will find this request very reasonable and admit that people whose life and jobs are directly threatened should not have to travel 900 km to access such vital documents to them. We recommend that public libraries in Sydney, North Sydney or Sydney Mines, Baddeck, as well as the Environment & Labour Department in Sydney, be the depositories of such documents. Such locations are opened longer hours, evenings and Saturdays, and the working public has a chance to view them.

We thank you for your attention and for giving us a chance to express our concerns and we trust these concerns will be heard and that you will give us a fair hearing because so far it has not been the case and the public has been royally and shamefully ignored.

Yours truly,

Signed by
Citizens Against Strip Mining

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Revised: 06/28/05 22:36:47.