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 Table 4: Alterations and destruction to aquatic habitat are also predicted in the ESR resulting from eastern corridor construction and operation activities (Draft ESR, page 3- 31). Environmental Effect Potential stream flow alterations may result from: Alterations to lake, pond, and stream water quality may result from: Destruction/Displacement of Fish Habitat may result from: GCU Related Activity Increased surface run-off during storm events due the clearing of vegetation. The removal of vegetation is known to decrease the rate at which water infiltrates the soil and increases run-off volumes, making small streams/creeks more vulnerable to flooding during storm events. Alteration of flow regimes caused by improperly installed culverts and addition of aggregates. Improperly constructed road crossings are known to increase erosion and gradients in downstream areas and can also impede flow with insufficient culvert size or when improperly installed Elevated levels of Turbidity, Total Suspended Solids, and Conductivity due to increased levels of erosion and sedimentation caused by the removal of riparian vegetation. Increased water temperatures during the summer months due the removal of riparian vegetation may increase the solar input to a stream causing water temperatures to increase above normal temperatures. Furthermore, increased levels of Total Suspended Solids caused by sedimentation and erosion also increase water temperatures as they retain more solar radiation. Improperly constructed road crossings will impede fish migration and alter substrate type due to changes in the flow regime. Changes in water temperatures due to erosion and sedimentation will affect species that are not resilient to warmer temperatures. Increased sedimentation will also fill in pools and under-cut banks, as well as covering essential spawning habitats such as gravel and cobble shoals. The mitigation measures proposed by GCU to remedy all the above potential impacts to aquatic habitat and flow alterations include implementing a buffer around lakes, ponds and streams and having an “experienced and respected professional engineer” as opposed to an inexperienced and disrespected unprofessional engineer (!?!?). The mitigation measures proposed do not discuss continued monitoring or follow-up actions if any of the above impacts are detected. 33
Gold Canyon Resources Inc: Final Environmental Study Report Review March 30, 2013 The ESR regards all potential impacts to lakes, rivers and streams to be low, without providing any rationale, or having the evidence to back up those claims. Recommendation: GCU needs to conduct a thorough aquatics study, taking into account the above-mentioned parameters, relevant to all Springpole exploration activities. The study should assess the environmental impacts for the duration of Springpole exploration project; 10-20 years. Recommendation: The next aquatics baseline study performed by GCU needs to take information gathered from the hydrology and terrestrial baseline studies and evaluate their combined effect on aquatic habitat, surface and deep water quality, species diversity, species reproduction, hydrology, etc. Recommendation: If GCU has determined that there are high levels of heavy metals detected in Springpole, all activities that could potentially contribute to increased heavy metal leaching must be stopped. 5.5 Hydrology Baseline Report Deficiencies Hydrology is the study of water movement, quality and distribution. Typical hydrological investigations include an assessment of ground water quality, character, composition and potential for contamination. The hydrological study conducted by GCU did not evaluate any parameters associated with ground water quality, or identify which aquifers may be impacted by Springpole drilling activity. The aquatics study should have been conducted in conjunction with the hydrology study in order to properly assess for downstream or ground water contamination: aquatics study revealed that heavy metals were already elevated in Springpole. In the Preliminary Economic Assessment released March 25, 2013, GCU states that Springpole exploration construction will include: “project infrastructure, dike construction and dewatering activities, open pit development, procurement of mining and milling equipment, and mill construction (GCU Preliminary Economic Assessment – March 25, 2013).” NO WHERE in the ESR or Technical reports (hydrology or aquatics) does GCU discuss dike construction, dewatering activities, open pit development or the required water and sewer infrastructure required to pursue continued/advanced exploration, that would occur pending approval of the eastern corridor. It is evident for the Preliminary Economic Assessment, that GCU is NOT being fully transparent about the full scope of the Springpole exploration project, nor the true environmental and socio-economic ramifications related to project activities. Recommendation: GCU needs to fully disclose ALL Springpole related exploration activities, inclusive of the eastern corridor, in a single document complete with technical 34
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- Page 361 and 362: GCU has hired qualified, independen
- Page 363 and 364: The basic environmental protection
- Page 365 and 366: 8. Like the Draft ESR, Notices were
- Page 367 and 368: A full record of consultation is pr
- Page 369 and 370: Page 7 1. Corridor alternatives pre
- Page 371 and 372: 13. “Stakeholders” refers solel
- Page 373 and 374: Page 10 1. Detailed comments on the
- Page 375 and 376: Page 13 1. GCU is proposing to clea
- Page 377 and 378: Page 15 1. GCU is open to developin
- Page 379 and 380: Page 17 1. The economic information
- Page 381 and 382: Page 18 1. This is not a requiremen
- Page 383 and 384: (which were not intended to describ
- Page 385 and 386: Page 21 1. Note that the OLT develo
- Page 387 and 388: Page 22 1. The statement that carib
- Page 389 and 390: Page 24 1. General comment on 5.3.2
- Page 391 and 392: Page 26 1. The background database
- Page 393 and 394: Page 29 1. Comments on Table 3: The
- Page 395 and 396: Page 31 1. Water quality at Springp
- Page 397 and 398: 9. The aquatics baseline report doe
- Page 399 and 400: assessed through toxicity testing a
<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 />
The ESR regards all potential impacts to lakes, rivers and streams to be low, without<br />
providing any rationale, or having the evidence to back up those claims.<br />
Recommendation: GCU needs to conduct a thorough aquatics study, taking into account<br />
the above-mentioned parameters, relevant to all Springpole exploration activities. The<br />
study should assess the environmental impacts for the duration of Springpole exploration<br />
project; 10-20 years.<br />
Recommendation: The next aquatics baseline study performed by GCU needs to take<br />
information gathered from the hydrology and terrestrial baseline studies and evaluate<br />
their combined effect on aquatic habitat, surface and deep water quality, species diversity,<br />
species reproduction, hydrology, etc.<br />
Recommendation: If GCU has determined that there are high levels of heavy metals<br />
detected in Springpole, all activities that could potentially contribute to increased heavy<br />
metal leaching must be stopped.<br />
5.5 Hydrology Baseline <strong>Report</strong> Deficiencies<br />
Hydrology is the study of water movement, quality and distribution. Typical hydrological<br />
investigations include an assessment of ground water quality, character, composition and<br />
potential for contamination. The hydrological study conducted by GCU did not evaluate<br />
any parameters associated with ground water quality, or identify which aquifers may be<br />
impacted by Springpole drilling activity.<br />
The aquatics study should have been conducted in conjunction with the hydrology study in<br />
order to properly assess for downstream or ground water contamination: aquatics study<br />
revealed that heavy metals were already elevated in Springpole.<br />
In the Preliminary Economic Assessment released March 25, 2013, GCU states that<br />
Springpole exploration construction will include: “project infrastructure, dike construction<br />
and dewatering activities, open pit development, procurement of mining and milling<br />
equipment, and mill construction (GCU Preliminary Economic Assessment – March 25,<br />
2013).”<br />
NO WHERE in the ESR or Technical reports (hydrology or aquatics) does GCU discuss<br />
dike construction, dewatering activities, open pit development or the required water<br />
and sewer infrastructure required to pursue continued/advanced exploration, that<br />
would occur pending approval of the eastern corridor.<br />
It is evident for the Preliminary Economic Assessment, that GCU is NOT being fully<br />
transparent about the full scope of the Springpole exploration project, nor the true<br />
environmental and socio-economic ramifications related to project activities.<br />
Recommendation: GCU needs to fully disclose ALL Springpole related exploration<br />
activities, inclusive of the eastern corridor, in a single document complete with technical<br />
34