Position Statement on Economic Development Activities in the Nashwaak Watershed
“Closing the Loop”
The NWAI recognizes that economic development activities are vital to the wellbeing and livelihood of those New Brunswickers privileged to call the Nashwaak River watershed their home. As such, we are committed to working with all relevant stakeholders to ensure that such activities meet and exceed best practices of environmental stewardship. Recreational, agricultural, forestry, and resource extraction industries all have a part to play in protecting the Nashwaak’s unique and important ecosystem, and the NWAI advocates a positive and engaged approach to working with these stakeholders for the benefit of all.
Because the Nashwaak River is largely pristine, our vision of economic development and environmental stewardship is fundamentally based on the concept of “closed loop” projects: projects begin with a healthy ecosystem, and are deemed to be completed only when the ecosystem is returned to the same healthy state. Each component of the project should be designed and executed with this “closed loop” in mind, informing best practices pertaining to all operations and plans for remediation.
With scientific and practical expertise in reforestation, erosion management and remediation, habitat evaluation, and water quality assessment, the NWAI is well positioned to offer criticism, provide advice, and monitor results pertaining to the impact of economic development activities on watershed health.
Position Statement on Federal Government Decision to Approve the Sisson Brook Mine
On June 23rd, 2017, the Honourable Catherine McKenna, Minister of Environment and Climate Change, determined that the Sisson Mine Project “is likely to cause adverse environmental effects” and “is likely to result in significant adverse environmental effects” on the current use of lands and resources for traditional purposes by the Maliseet First Nations, but otherwise is “not likely to cause significant adverse environmental effects on other components of the environment” and deems that “the mitigation measures and follow-up program described in the Comprehensive Study Report are appropriate for the Project.” Subject to mitigation measures, this determination provides approval for the Sisson Mine Project to move forward.
The December 2015 “Conditions of Approval” for the project from the New Brunswick government include 40 conditions, including permits, revised modelling for the tailings storage facility, a water monitoring/management plan, a wetlands compensation plan, a water supply source assessment, a financial security plan (including both mine reclamation securities and environmental securities), a pre-construction survey to establish baseline environmental conditions, an environmental and socioeconomic management system, an emergency preparedness and response program, a comprehensive environmental management plan, and comprehensive tailings storage facility failure modelling. We wholeheartedly support these conditions, and we call for the results of their implementation and management to be made available to the public as part of an ongoing process of dialogue and community engagement.
The Nashwaak Watershed Association’s position on economic development activities in the Nashwaak watershed is one that emphasizes environmental stewardship and the idea of “closing the loop”, whereby any project or activity is only deemed to be complete once the environment is returned to the environmental condition in which it began. With that in mind, we hope to be able to work with all stakeholders with an interest in the Sisson Mine Project to ensure that the highest standards of environmental stewardship are utilized throughout the life of this project.
In the aftermath of the breach of the tailings storage facility at the Mount Polley Mine in British Columbia in 2014, the Government of British Columbia established the Independent Expert Engineering Investigation and Review Panel to investigate the causes of this incident and to make a series of recommendations on how to prevent similar failures in the future. In their recommendations the panel writes that “the path to zero failures involves a combination of best available technology (BAT) and best applicable practices (BAP)” and recommends that “BAT should be actively encouraged for new tailings facilities at existing and proposed mines” (p. 139). In their report the panel rejects the concept of a “tolerable failure rate for tailings dams” (p. 119), and notes the intrinsic hazards associated with dual purpose impoundments storing both water and tailings (p. 121). They are unequivocal in recommending filtered or “dry-stack” tailings as the best available technology for tailings management, and note that economic factors cannot “continue to pre-empt best technology” (pp. 122-3).
In October of 2017, the Mining Association of Canada (MAC) published their Guide to the Management of Tailings Facilities (3rd Edition), an integral part of the Towards Sustainable Mining initiative that is mandatory for all of their members for their operations in Canada. It is updated to reflect the MAC’s comprehensive internal and external review of their tailings management protocols in the light of the tailings failure at Mount Polley. The newest Guide emphasizes a focus on Best Available Technology (BAT) and Best Applicable Practices (BAP) for the management of tailings, and requires an independent review of the design, maintenance, and afterlife of tailings facilities. The NWAI supports these protocols in any case where mining occurs throughout the Nashwaak River watershed.
Dry stack tailings storage on ecologically less sensitive high elevation forest land—as far away from highly sensitive riparian low elevation land as possible—with the stacks capped with soil and reforested after completion is considered to represent the best available technology for mitigating the environmental impact of mineral extraction industries. This approach was recommended by the NWAI in its first submission on the proposed Sisson project in 2009, and we maintain it should be considered as the preferred approach. If the tailings cannot be handled in a manner that guarantees no damage to the watercourse—in perpetuity—then the project should not be allowed to proceed. The NWAI is concerned about impacts to the Nashwaak River, primarily due to the riparian proximity of the proposed tailings pond. These tailings must be handled in a manner that protects the watercourse.
The NWAI recognizes that mining is an essential economic activity, but insists that mining must be done using best available technology to protect the environment generally, and the Nashwaak River in particular. Accordingly, we will continue to work closely with The Sisson Partnership, with the Provincial and Federal governments, and with other stakeholders, to ensure that the mine’s operations meet the highest levels of environmental stewardship and to protect the Nashwaak River for future generations of New Brunswickers.