Revised Final Environmental Study Report (24 MB) - Gold Canyon ...
Revised Final Environmental Study Report (24 MB) - Gold Canyon ... Revised Final Environmental Study Report (24 MB) - Gold Canyon ...
Gold Canyon Resources Inc: Final Environmental Study Report Review March 30, 2013 sampled, 53% of them were unclassified and did not match up with existing FRI data, which was attributed to “lack of accurate data for the current FRI (Terrestrial Baseline Report, page 3-3).” Overall, there are a variety of areas where the study was deficient; All 23 selected ecosites were within a small region of the larger study area, and were not representative of the overall study area or the eastern corridor; The study failed to determine what vegetative species were present in the area through field work; No reference made to the forest fire and cumulative impacts to vegetation; No discussion regarding harvesting 645 km2 of timber and its impacts on vegetative biodiversity; No discussion on how the eastern corridor would impact endangered, threatened, special concern or extirpated vegetative species; No environmental protection and mitigation measures proposed for vegetative species at risk; No discussion on potentially important wildlife plant food sources that may be compromised; No statistics provided to determine accuracy of reporting. As with the other terrestrial baseline studies, conclusions were drawn about the low impact of the project on terrestrial parameters, based on flawed methodology and lack of data: “None of these stands have been found to occur within the RSA, therefore the potential environmental effects are considered to be negligible and no mitigation is required (Draft ESR, page 3-28).” Based on the narrow analysis used to derive these unsubstantiated conclusions, it is fair to say that this study was unscientific, poorly conducted and results are inconclusive. Recommendation: GCU needs to conduct a thorough fieldwork vegetation study in conjunction with First Nation communities that documents all ecosites, plant species and communities relevant to the eastern corridor. Recommendation: During the next vegetation study, GCU will document the plant species that are listed in the Ontario Species At Risk - Vascular Plants list, and those that are used within First Nation traditional purposes. Recommendation: The road closure and rehabilitation plan developed for the eastern corridor needs to have all plant communities well documented, and outline how revegetation will occur in order to return those sites back to their original states. 30
Gold Canyon Resources Inc: Final Environmental Study Report Review March 30, 2013 5.4 Aquatics Baseline Report Deficiencies Mining activities cause significant contamination of water resources, and generally proceed with little regard for the environment. GCU has been conducting exploration activities in Springpole for many years, however their environmental analysis of the area was conducted in 2011. Any results generated from the Springpole area aquatics study will be biased, as drilling activity on the lake may have already altered aquatic baseline values. After a preliminary review of the aquatics study and technical report findings, there are a few issues pertaining to reporting in the ESR; 1) The Birch River crossing was not assessed within the Aquatics Baseline Study. The site is referenced as being important for all season and spawning habitat for fish. “The Birch River has its outflow at the eastern end of Springpole Lake, draining Springpole into Fawcett Lake. The Birch River is known to provide some of the most important walleye spawning habitat in the study area and may serve as year-round habitat for walleye. Lake trout, northern pike and whitefish all likely show seasonal use of the river, as either feeding (lake trout, northern pike, whitefish) or spawning (whitefish) habitat. The drainage from Cromarty Lake into the southwest corner of Springpole Lake also represents important walleye spawning habitat in the study area (Draft ESR, page 2-35).” 2) The ESR does not discuss surface water results within the ESR, as it is not directly related to the eastern corridor. Given that all of the technical report studies were conducted at locations not relevant for the eastern corridor, it is only fair that surface water results also be analyzed here. Surface water results from the Aquatics Baseline Report (page 24); Total phosphorus was higher than Provincial Water Quality Objectives (PWQO) of 0.02 mg/L at sites; SW-6 (0.026 mg/L) in Q1, SW-9 (0.023 mg/L) in Q2, SW-4 TOP (0.022 mg/L), SW-5 TOP (0.032 mg/L), SW-9 (0.049 mg/L), and SW-10 (0.042 mg/L) in Q3. Dissolved mercury was higher than the PWQO of 0.2 μg/L at sites; SW-3 (0.43 μg/L) and SW-5 (0.27 μg/L) in Q1, as well as in SW-5 MID (0.29 μg/L) in Q3. Total cadmium was higher than the PWQO of 0.1 μg/L (sample hardness measured at less than 100 mg/L) at SW-11 (0.4 μg/L) in Q1. Total iron surpassed the PWQO of 300 μg/L at sites SW-9 (850 μg/L) and SW-10 (970 μg/L) in Q3. Note: technical report did not indicate where the actual sampling locations were. The report indicates that total phosphorous, dissolved mercury, total cadmium and total iron are already elevated in the study area. No rationale as to why these elements were already elevated in surface water samples within the technical report and ESR, particularly the heavy metals; mercury, cadmium and iron. 31
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<strong>Gold</strong> <strong>Canyon</strong> Resources Inc: <strong>Final</strong> <strong>Environmental</strong> <strong>Study</strong> <strong>Report</strong> Review<br />
March 30, 2013<br />
5.4 Aquatics Baseline <strong>Report</strong> Deficiencies<br />
Mining activities cause significant contamination of water resources, and generally proceed<br />
with little regard for the environment. GCU has been conducting exploration activities in<br />
Springpole for many years, however their environmental analysis of the area was<br />
conducted in 2011. Any results generated from the Springpole area aquatics study<br />
will be biased, as drilling activity on the lake may have already altered aquatic<br />
baseline values.<br />
After a preliminary review of the aquatics study and technical report findings, there are a<br />
few issues pertaining to reporting in the ESR;<br />
1) The Birch River crossing was not assessed within the Aquatics Baseline <strong>Study</strong>. The<br />
site is referenced as being important for all season and spawning habitat for fish.<br />
“The Birch River has its outflow at the eastern end of Springpole Lake, draining Springpole<br />
into Fawcett Lake. The Birch River is known to provide some of the most important walleye<br />
spawning habitat in the study area and may serve as year-round habitat for walleye. Lake<br />
trout, northern pike and whitefish all likely show seasonal use of the river, as either feeding<br />
(lake trout, northern pike, whitefish) or spawning (whitefish) habitat. The drainage from<br />
Cromarty Lake into the southwest corner of Springpole Lake also represents important<br />
walleye spawning habitat in the study area (Draft ESR, page 2-35).”<br />
2) The ESR does not discuss surface water results within the ESR, as it is not directly<br />
related to the eastern corridor. Given that all of the technical report studies were<br />
conducted at locations not relevant for the eastern corridor, it is only fair that<br />
surface water results also be analyzed here.<br />
Surface water results from the Aquatics Baseline <strong>Report</strong> (page <strong>24</strong>);<br />
Total phosphorus was higher than Provincial Water Quality Objectives (PWQO)<br />
of 0.02 mg/L at sites; SW-6 (0.026 mg/L) in Q1, SW-9 (0.023 mg/L) in Q2, SW-4 TOP<br />
(0.022 mg/L), SW-5 TOP (0.032 mg/L), SW-9 (0.049 mg/L), and SW-10 (0.042 mg/L)<br />
in Q3.<br />
Dissolved mercury was higher than the PWQO of 0.2 μg/L at sites; SW-3 (0.43<br />
μg/L) and SW-5 (0.27 μg/L) in Q1, as well as in SW-5 MID (0.29 μg/L) in Q3.<br />
Total cadmium was higher than the PWQO of 0.1 μg/L (sample hardness<br />
measured at less than 100 mg/L) at SW-11 (0.4 μg/L) in Q1.<br />
Total iron surpassed the PWQO of 300 μg/L at sites SW-9 (850 μg/L) and SW-10<br />
(970 μg/L) in Q3.<br />
Note: technical report did not indicate where the actual sampling locations were.<br />
The report indicates that total phosphorous, dissolved mercury, total cadmium and<br />
total iron are already elevated in the study area. No rationale as to why these<br />
elements were already elevated in surface water samples within the technical report<br />
and ESR, particularly the heavy metals; mercury, cadmium and iron.<br />
31