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Please note that LACC is an informal, voluntary, non-profit community organization committed to the opposition of the McBride Nickel-cobalt-copper Project in Limerick, and does not have memberships. However, as a matter of liability
regarding any possible inaccuracies or misrepresentations, anyone stating that they are representatives of LACC must first receive written confirmation from LACC authorizing the release of any documents or public statements on behalf of LACC.

LACC does not have memberships.

Anyone of the public can act as their own individual as they see fit regarding any issues.

Please send your comments/concerns to:

Mr. Tony Scarr
Regional Supervisor Southern Ontario
Ministry of Energy, Northern Development and Mines (MNDM)
933 Ramsey Lake Road, Floor 6
Sudbury ON P3E 6B5
Email: tony.scarr@ontario.ca

AND

Hon. Greg Rickford
Minister of Energy, Northern Development and Mines
99 Wellesley St W, Whitney Block 5th Flr Rm 5630
Toronto, ON, M7A 1W3
email: greg.rickford@pc.ola.org

  • Your work in the Ministry is vital for Ontario’s economy and it’s non-renewable resources. The People are reliant on your efforts to ensure fairness and wise oversight of our environment for our future generations.
  • Government bodies at all levels have the ability, and obligation to intervene prior to such damage occurring, minimizing “environmental disturbances during all phases of mining, recognizing that prevention is more effective than remediation and rehabilitation of an environmental problem.”
    (Statement of Environmental Values, MNDM).
  • The target area for the mine is 880 hectares (2174 acres) of unspoiled, forested land in Limerick Township.
    Year-round residents depend on this natural environment for their livelihood and well-being. The dust produced would be toxic, carried in excess of 50km and has a bio accumulative effect. Vegetation and animals would be negatively affected, especially for human consumption.
  • Continual dump truck traffic would prematurely break down our roads adding to municipal expenses. The truck routes could either travel through Bancroft on their way to Sudbury for processing or go down Hwy 62 towards the Belleville rail lines, creating traffic congestion and further road deterioration in multiple townships.
  • This early stage exploration involves clear cutting, mechanized pitting and trenching exposing sulphur bearing rock, as well as large amounts of water taking with sulphuric waste water run off leaching into waterways causing irreparable environmental destruction including several lake systems and drinking
    water contamination.
  • Toxic air borne contaminants can carry for 50+ km having a bio accumulation effect affecting lungs, kidneys and cardiovascular systems. Many residents have relocated here from cities because of health issues such as asthma, which disappeared when living here because of our clean air.
  • Explorations and mining activities will leach out water and air borne toxins to marine and land wildlife habitats affecting several endangered and threatened species, as well as negative impacts on hunting and fishing.
  • Tourism for local leisure activities such as McGeachie Trail, Heritage Trail and lake activities will be negatively impacted, also affecting small businesses.
  • Please note that I’m not against mining as it provides a necessary resource. As a resident, I’m opposed to this location because of the wide spread negative environmental impacts the community and myself will suffer because of the explorations and potential mine.
  • Any local employment through the mine would be low paying and negligible as most skilled labour would be outsourced. 5 million tons of mine wastes could be generated with a continual stream of dump trucks on main roads possibly traveling through Bancroft toward Sudbury or to Belleville railway, contributing to
    dust, congestion, and road disrepair, which our limited infrastructure can’t effectively manage.
  • Many seasonal residents and visitors come to Limerick year after year because of the health benefits and beauty of our lakes, wetlands, and woods. A mining operation would seriously damage tourism and recreation, which many local businesses depend upon.
  • A mine will produce sulphuric acid and toxins, destroying our lakes, streams, and wetlands, harming wildlife, some of which are threatened or endangered in that area including the Blandings Turtle, Spotted Turtle, Eastern Whip-poor-will, American Eel, Algonquin Wolf and Eastern Hog Nosed snake.
  • The mine would produce up to 5 million tons of waste. This waste will have to be contained forever, which is costly and proven unsafe. Over a dozen mining-waste spills have occurred in Canada in the last 10 years. The recent dam collapse in Brazil, and Mount Polley in BC as examples.
  • Exploration drilling and other mining activities – even from test holes – can travel long distances through out the underground watersheds affecting thousands of people. Drinking water from wells would be contaminated with sulphuric acid and sediment.
  • There is majority local opposition to the mine, as well as over 2200 signatures received on petitions opposing the mine.
  • The companies involved have not gained the community’s trust. They have been line-cutting and flagging private property without proper notification of the owners.
  • Ontario is the only province that does not require a full Environmental Impact Study (EIS) for mining projects BEFORE habitat and watershed destruction has begun. According to Ontario mandates, clear cutting, pitting and trenching can occur BEFORE the EIS. Therefore any habitats such as endangered or at-risk species, Blandings Turtle, Spotted Turtle, Eastern Whip-poor-will, American Eel, Algonquin Wolf or Eastern Hog Nosed snake would be irreparably destroyed with no criminal consequences.
  • Ontario is the only province in Canada that does not require an Environmental Impact Study for mining projects. Common sense should tell us that this mining property cannot be developed without causing irreversible harm to local habitats. The only reasonable solution is to deny all further permits to proceed with this venture. The potential benefits to the community are slim, and the risk to our environment and our way of life has historically proven detrimental on every level.
  • Limerick and neighbouring townships are part of “The Land Between” – an important ecological zone between the St. Lawrence Lowlands and the Canadian Shield only approx 50km wide. This region has unique geological, ecological, and cultural features and has the highest level of habitat diversity in Ontario. The natural habitat of Limerick and area supports several endangered or at-risk species, such the Blandings Turtle, Spotted Turtle, Eastern Whip-poor-will, American Eel, Algonquin Wolf and Eastern Hog Nosed snake.
  • Property values would decline in the immediate and surround areas, and residents may be unable to sell their homes or cottages. This would have an immediate impact on local business are residents move out of the areas and do not invest in home renovations.
  • While mining is a necessary resource on Ontario, discretion needs to be made regarding locations.
    Hastings County and area were once active in the mining industry and culture, the mining railway was removed over 30 years ago and is now a prominent tourist attraction spanning 191km. This Heritage Trail travels directly through the northern mining site.
  • An excerpt from a 2016 report from the Auditor General stated: “as of March 31, 2015, the government identified that it had a liability of $1.2 billion to clean up 47 contaminated sites that were caused by mining in Ontario over the years.”
  • With an official government estimate of $3.1 billion in liability for both active and abandoned mines, a 300% increase over 10 years, MiningWatch reports that Ontario ranks first in Canada as having the biggest environmental liability in the mining sector. Meanwhile, both MiningWatch and the Auditor General note that Ontario generated less than 1.3 billion in mine royalties over the same period, and is offering one of the lowest—if not the lowest—effective tax rate in Canada (less than 6%). (MiningWatch Canada Report, Sept 2018).
  • MiningWatch Canada- “With an official government estimate of $3.1 billion in liability for both active and abandoned mines, a 300% increase over 10 years, MiningWatch reports that Ontario ranks first in Canada as having the biggest environmental liability in the mining sector. Environmental challenge is to contain the mine waste in perpetuity, ensuring that pollution never leaks into surficial or underground waters, and that the project is not subject to a catastrophic spill or other major environmental accidents. Zero risk does not exist and there are over a dozen mining spills reported in Canada over the last decade.”
  • MiningWatch Canada-“Ontario remains the only province in Canada that does not require a comprehensive environmental impact assessment for mining projects. Specific provisions of the Ontario Mining Act and associated regulations, or another relevant ministry, under different legislations, such as the Ministry of Environment, with the support of the government, gives MNDM the authority to deny Plans/Permits on the basis of potential harm with known existing ecosystems.”
  • I strongly oppose the McBride Project for two main reasons. First, its risks to the environment are unacceptable. Second, it will not benefit the community. Please deny or revoke any exploration Plans or Permits for the project.
  • Our bedrock aquifers are sensitive to drought and vulnerable to contaminants. Mining Watch Canada estimates that, if put in operation, the mine could generate “up to 5 million tons of potentially acid generating mine waste.” This waste would need to be contained indefinitely. Even exploratory drilling could release sulphur into wells. The contaminants introduced into ground water would pollute nearby lakes, streams, and springs and could travel as far as Lake Ontario.
  • My opposition to the development of a mine is not just about vacation time at cottage. It is about preserving a unique environment for my children, grandchildren, and generations to come, and for those who make the Limerick area their home. The environment can’t be restored to it’s natural habitat, even with early exploration activities.
  • The mining property covers a forested area in the headwaters of Beaver Creek, within the Crowe Valley watershed, which feeds many unspoiled lakes and ultimately drains into Lake Ontario. The target area contains an intricate system of wetlands. It is well understood that wetlands are essential to the health of
    ecosystems. They are a natural purification system for groundwater and provide vital habitat for an immense range of plants, insects, fish, amphibians, turtles, reptiles, mammals, and birds. Wetlands help to recharge underground aquifers, provide a buffer against flooding, and protect against wildfires.
    Poisoning the wetlands and lakes in Limerick and adjoining townships with toxins from mining waste would be an environmental and social disaster that cannot be reversed. Exposing rich habitats to this risk is completely at odds with efforts made for over 30 years by federal, provincial, and local agencies to reverse wetland loss.
  • Pancon has told its shareholders that the McBride Project is located in a region with “strong community support” for mining. This is an outdated view of our community. Of the more than 250 people who, despite inadequate notice, attended an information meeting at the Limerick Community Centre on September 9, the community expressed strong opposition to the project. Moreover, the companies involved have not inspired trust: line-cutting and flagging were carried out this summer without appropriate consultation with or notification of residents and First Nations.
  • Although mining ventures were, historically, common in the area, there is no appetite for resource extraction any longer. Economic growth has diversified into local services and trades, entrepreneurship, tourism and recreation, while the traditional activities of hunting, fishing, trapping, small-scale logging and farming continue. An industrial mining operation has no value for most year-round and seasonal residents, will not generate a meaningful number of desirable local jobs, will reduce property values, and will not add to the municipal tax base.
  • The most precious assets of Limerick and area are its natural environment and the responsible stewardship of that environment. A healthy and prosperous future for our community lies in a low-impact, sustainable economy based in enjoyment of and respect for that environment. The construction and operation of a mine would contaminate ground and surface drinking water, further endanger threatened species, displace wildlife, and undermine the three-fold seasonal increase in population and the economic benefits that provides.
  • There would be continuous noise pollution from truck traffic, heavy equipment and blasting as many mines operate 24 hours. After a mine is closed, it can become a prime target to be used as a landfill site.
  • The proposed mining area entails known significant ground recharge areas vital for clean water sheds spilling out into several lakes among along with numerous creeks and streams leading to Lake Ontario. There are Environmentally Protected areas, deer wintering areas, American eels which are under consideration for endangered/threatened listings, and several other threatened and endangered species and habitats vital for their life processes through out the entire mining area.
  • Our area contains hamlets which depend on tourism and outdoor recreations both locally and in the nearby towns of Madoc and Bancroft. Mining was once common in these areas, mineral concentrations in southern Ontario historically are very low grade, but leave behind reminders such as the toxic Deloro mine site (70 million remediation 2014) which is still emitting approx 10kg/day arsenic daily and is contaminated with nickel, cobalt, copper, and low level radioactive waste.
  • This Crowe Valley Conservation watershed, inclusive of the McGeachie Conservation Area, consist of Environmentally Protected areas and headwaters which feed many private wells and a multitude of fish abundant lakes and streams leading to Lake Ontario. Recreational forested grounds and marshes are outlined with permanent and seasonal residents. Our Land Between ecotone is home to many endangered and threatened species that coalesce from the northern and southern climates. This transition zone is only 50km wide, yet there is a higher biodiversity of wildlife and vegetation than anywhere else in Ontario, which can effectively withstand climate change. This is the last refuge for over 100 species at risk. These “lungs” of the environment are being eradicated with southern Ontario’s urbanization sprawl, therefore are of more importance than ever.
  • The “McBride Project” nickel, cobalt and copper mining area involves 880 hectares of private and Crown land. Because of the shallow fractured rock and the volcanic geological properties of the aquifers, the flow of surface water will often deviate dramatically and unpredictably in the sub aquifers, affecting not only southern water bodies and lakes but also northern water bodies.
  • The sulfide concentration released by earth and rock disturbances characteristic of mining activities are exacerbated, even in early explorations. For example, surface stripping involves high water pressure thousands of kg/square cm displacing otherwise dormant sulfides. Copper, chalcopyrite, is itself a copperiron-
    sulfide, are often major culprits of acid mine drainage. The toxic, carcinogenic dust produced from this type of mine can travel many tens of kilometers, negatively affecting every living organism.
  • With Pancon’s current early exploration stage, and more core sampling necessary to determine whether the current assays are better than the historic low grade ore, MNDM may take the initiative to deny further explorations applying the precautionary principle with known environmentally sensitive factors,
    mitigating unnecessary expenses and resources from all sectors involved in this mining venture.
  • MiningWatch Canada-“At times, the MNDM, may take action to deny Permit and face potential litigations, which at this early stage would be comparatively more manageable as opposed should the Project advance further. A recent court decision (Eebatmatoong First Nation) did quash an early exploration permit because of inadequate consultation with a First Nation in Ontario. Future developments of this case are pending.” Alderville First Nation, Chief Marsden acknowledged they were not duly consulted, Sept 9, 2018.
  • The Auditor General of Ontario (AGO) denounced the lack of mandatory environmental impact assessments in Ontario in its 2016 report: “The Act is 40 years old— and is, in fact, the oldest environmental assessment legislation in Canada — it falls short of achieving its intended purpose Ontario’s environmental assessment process needs to be modernized and aligned with best practices in Canada and internationally.” “These projects—such as mining operations…—proceed without an up-front evaluation of the environmental impacts of the project. Such impacts can be extensive and can affect Ontarians for many years. For example, as of March 31, 2015, the government identified that it had a liability of $1.2 billion to clean up 47 contaminated sites that were caused by mining in Ontario over the years.” “….Tailings from copper and uranium mining often produce measurable levels of radioactivity.”
  • Canadian Environmental Protection Act: 2 (1) (a) (the Government of Canada shall) exercise its powers in a manner that protects the environment and human health, applies the precautionary principle that, where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation, and promotes and reinforces enforceable pollution prevention approaches.
    (j) protect the environment, including its biological diversity, and human health, from the risk of any adverse effects of the use and release of toxic substances, pollutants and wastes.
    Whereas the Government of Canada will endeavour to remove threats to biological diversity through pollution prevention, the control and management of the risk of any adverse effects of the use and release of toxic substances, pollutants and wastes, and the virtual elimination of persistent and bioaccumulative toxic substances.
  • Ontario’s Endangered Species Act– Prohibits the damage and destruction of the habitat of endangered and threatened species, some of which carry out life processes in wetlands.
  • Canadian Environmental Assessment Act- …. federal authorities and responsible authorities…. must exercise their powers in a manner that protects the environment and human health and applies the precautionary principle. 4(1)(a) …to protect the components of the environment…. from significant adverse
    environmental effects caused by a designated project.
    1.1.1 Provincial Policy Statement: c)…..avoiding development and land use patterns which may cause environmental or public health and safety concerns. h) promoting development and land use patterns that conserve biodiversity and consider the impacts of a changing climate. 2.2.1 Planning authorities shall protect, improve or restore the quality and quantity of water by: d. maintaining linkages and related functions among ground water features, hydrologic functions, natural heritage features and areas, and surface water features including shoreline areas.
  • Statement of Environmental Values: Ministry of Northern Development and Mines
    1.The prevention, reduction and elimination of the use, generation and release of pollutants that are an unreasonable threat to the integrity of the environment.
    3.The protection and conservation of natural resources, including plant life, animal life and ecological systems.
    5.The identification, protection and conservation of ecologically sensitive areas or processes.
    APPLICATION OF THE SEV -Recognize that environmentally sustainable development of Ontario’s mineral resources requires an understanding of the ecological, physical, social and economic impacts of development on a project by project basis.
    -Protect natural heritage and biological features of provincial significance; [ie The Land Between]
    Specifically with respect to MNDM’s mining responsibilities, the Ministry will promote environmentally sustainable mining activity which: Eliminates long-term effects on the environment;
    In cooperation with other ministries, minimizes environmental disturbances during all phases of mining, recognizing that prevention is more effective than remediation and rehabilitation of an environmental problem.
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