Upper Beaver House Gold Project Comment

I thank you for the ability to comment on this project.
My hope that this comment is received with the sincerity & concern with which it has been written.

As an owner of a residence on the Misema River downstream from Beaver House, Ava and York Lake (the proposed Upper Beaver House Project site).  There is a large concern with the detrimental environmental effects that the proposed project could have on the overall health of the surrounding ecosystems/ fish habitat recreation & drinking water for our families and animals as well as others who live or cottage to the adjacent areas.

There has been a multitude of concern shown from the public, indigenous communities and many environmental groups regarding the concern over the huge potential for this project distrub the surronding ecosysems & to pollute the environment with toxic chemicals, heavy metals, seasonal/stormwater run-off from tailing ponds and waste water effluent.

Seeing as the Misema River forms the catch basin for three provincial parks:

Gem Lake, Pushkin Hills, Esker Lakes;

The project can negatively impact the fishing colonies that migrate between these watersheds with a devastating impact on reproduction, life & toxic load along with habitat destruction ( York Lake).  This would indirectly have a huge negative impact on the overall health of the animals, humans and migration of birds that depend on these fish colonies as a food source.

The concern extends into the future plans that the proponent has for Ore processing after the onsite ore recourse is depleted.  Thier suggestion of potentially processing ore from other ore bodies would significantly increase the environmental impacts to the direct area and downstream watershed as this would allow the "project site" to become an extended processing site which could be much greater than the 16 year timeline initially proposed in the project details.  If this is the case the impacts of the operation would likely cause significant negative impacts for the surrounding environment for much larger time frame.

Concerned about the potential for these substances to pollute surface and groundwater, and how it would impact the communities and valued ecosystems. As the wastewater effluent is proposed to flow downstream from the project into the Misema River, this could have significant negative health consequences for all ecological processes, fish habitat, wildlife & families who live on vacation downstream of the project site which will extend for many kilometres through several lakes & riverine ecosystems.  The Misema River is a water source all those who live along the Miema River, Blanche River which connects to other water source and continues to flow downstream to Timiskaming Lake and the Tri cities.

The extreme concern is in regards to the seepage from tailings, waste rock , ore and overburden stockpiles.  Noting that the tailing storage facility is proposed to be located at a higher elevation and immediately above Beaverhouse Lake, local communities, cottagers and residents downstream on the Misema.  If this proposed infrastructure were to fail and/or run-off or seepage from it were to seep into Beaverhouse Lake it could contaminate all habitats, drinking water and ecosystems within and downstream.  

There was a very little information about how and to what extent the waste water effluent would be treated, how stormwater/seasonal run-off would be handled and treated, containment ponds and contents of ditches would be treated, how the environment would be protected from the seepage of those containments.  It needs to be stated what mitigation measures would be put in place to protect the surface water quality, fish and fish habitat in the surrounding lakes, creeks and wetlands from uncollected seepage and stormwater/seasonal run-off from the project area.

The dewatering York Lake and diverting the Misema River is an extreme measure that would displace fish, destroy fish habitat, and represent a potential cost to the fishery, local cottagers, Indigenous communities and downstream residents.  With this dewatering of York Lake and the diversion of Ava Lake it is very concerning that the accumulated downstream sediments and contaminates from past mining activities in the area would be stirred up and sent downstream when water flow is redirected through the Misema River system at the aid of four new dykes placed at the west end of Ava Lake and below York lake ( the proposed open pit mine) diverting the Misema River into two new diversion channels joining Ava lake directly to the Misema River downstream to York lake.

Regarding the dewatering of York Lake to make an open pit mine should be noted that "Open Pit Mines" result in a larger area of surface disruption and tend to produce much larger amounts of waste rock, while underground mines remove ore using shafts and ramps as well as other underground infrastructure and the ratio of waste rock to ore generated tends to be much lower.  Questioning the stated rationale for the open pit mine in terms of safety and stability.  The potential negative impacts from an open pit mine versus an underground mine would mean increased waste rock, noise, air, vibration, dust, light and effluent pollution and the loss of York lake.   I beleive that the pollution potential of an open pit mine on the surrounding surface water and natural environment has not been fully taken into account.  Even if York Lake was refilled with water again after the decommissioning of the mine, how suitable would it actually be as a fish habitat with no natural ecosystem left.

It has been indicated that the proponent determined with little information provided that an underground mine under York Lake was unstable and unsafe or the nature and detail of these conditions, other than approximately 20 meters(m) of unconsolidated materials and 20 M of bedrock are present above the proposed mine.  It is reported that "AE and their technical consultants are concerned that mining under these materials could cause an instability, and potentially a catastrophic failure and collapse of the underground workings, causing the Misema River to flow into the underground mine".     

A separate Independent Environmental Assessment should be performed by another company that is not directly affiliated with the proponent.  There is a complete conflict of interest for the acceptance an Environmental Assessment that is performed by a third-party company that could have a bias as they have been hired and paid for by the company that will benefit from the project approval.

This project should be halted until multiple year study can be performed by more than one company that can accurately depict the fluctuations of watershead through all seasons over a number of years as this can change drastically from year to year and season to season.  As flucuations in preciptation would directly impact the run off from the tailing ponds.  Note that very little information has been given with the estimates of an increase or decrease in water elevations on the Misema River south of the project site. Information on the diversion of such a large amount of water is vital for all those who live on or below the project site.

There are still some conerns in which I have not commented on, as others who have made comments are much greater edcuated and versed in those areas.  I only ask that you have an open heart and take all of what is expressed into account when reading these comments.  Noting that the surrounding area is home to many and as the world is today our natural ecosystems are becoming more valued everyday.  I undertand that natural resources are an important part of our economy, however our natural water sources and ecosystems should not be polluted or destroyed for the gain of a corporation when other mitigated measures could be put in place to set the health of the enviroment ahead profit. 

Again I thank you for your time and consideration while reviewing this comment

Blessing to all who take this into account.