Donkin Coal Environmental Problems

They arrived, then left us…with significant environmental risks

The Environmental Problems

The Donkin underground submarine mine that abruptly ceased operations on March 30, 2020 on the Donkin Peninsula in Cape Breton Island, only three years after starting production, has left the Province of Nova Scotia and Canada with significant ongoing environmental issues, three of which are uncontrolled greenhouse gas emissions, adverse noise pollution and wildlife including migratory birds at risk.

Donkin Mine, Cape Breton Nova Scotia
Donkin Mine, Cape Breton Nova Scotia

Mitigation Failures

From the outset the Donkin coal mine was known to be a very high emitter of methane gas.

It was so large that it necessitated the submission of a federally required Greenhouse Gas Management Plan; and so large that the provincial government tendered a report to provide "available options, including technologies and practices to minimize the carbon footprint, of underground coal mining." The province's report was to be used to assess the Donkin mine's greenhouse gas emissions plan.

The Donkin mine is now closed and idled, but the Pandora's box has been opened and there is no control of post-production liberation of fugitive methane emissions from the mine, the province of Nova Scotia will be forced to keep the mine's ventilation system running indefinitely.

Because of the mine's ventilation system to dilute methane gas, local residents and wildlife are experiencing a significant change in their acoustic environment and the associated cumulative health effects.

A BRIEF HISTORY

One year ago, during the month of May in 2019, Donkin mine experienced a methane fire, leading to a stop-work order being issued by the Department of Labour.

Three months later, in August 2019, to further increase efficiency of diluting methane out of the mine, the Donkin mine replaced the existing fans with two larger ventilation fans without installing the supplied silencers.

Global Warming

Methane Gas Exhaust Tunnel at Donkin Mine
Methane Gas Exhaust Tunnel at Donkin Mine

As evidenced in the above photograph of the exhaust tunnel at the Donkin mine, besides atmospheric dilution, there is no other mitigation control of post-production liberation of methane emissions from the Donkin mine.

Because fugitive methane emissions are not being captured and oxidized to CO2, methane gas emissions are substantial and are considered a large emitter of greenhouse gas emissions.

Reduction of these potent emissions from the Donkin mine should be a policy priority due to methane’s high global warming potential, which is 28 to 34 times greater than that of CO2.

The on-the-ground reality counters the following statement submitted with the Donkin mine's Environmental Impact Statement.

  • "The Project is committed to controlling its greenhouse gas (GHG) emissions from the Project through development and implementation of a GHG Management Plan and use of methane management technologies."

In addition, back in the beginning of the year of 2016, Premier Stephen McNeil said ...

  • "There's new technologies today".

Without the implementation of those new technologies, the cumulative effects of global warming are deemed to be high in magnitude, permanence, and significance for our children.

Public Health

Attenuation by distance across Morien Bay has not protected local residents from health risks and the expectation of "peace and quiet" from significant noise levels emanating from the mine, as evidenced by the following map highlighting the the mine's ventilation system pointed in a southwest direction coinciding with locations (orange dots) where residents are experiencing elevated noise levels. In effect, the use of larger fans without silencers has produced more noise pollution.

Local Communities Affected: Orange
Local Communities Affected: Orange

The adverse noise levels are producing the following negative effects for residents:

  • Disruption of sleep and the associated cumulative ill-health effects, for example: stress, fatigue and mood changes.

  • Significant acoustic change of rural ambient environment.

In addition, machinery that moves air, for example a mine ventilation system, creates low frequency energy which can cross great distances with little energy loss due to attenuation. Low frequency energy is harmful, therefore should be given serious consideration.
Source: World Health Organization. 1995.

As stated in the former Canadian Environmental Assessment Agency (now Impact Assessment Agency of Canada) 2013 report entitled, Comprehensive Study Report: Donkin Export Coking Coal Project.

  • "The proponent will monitor noise levels and implement a NSE-approved complaint management process that will include investigating and addressing any identified complaints."

Without the company addressing complaints, the adverse noise will continue to harm local communities because the province of Nova Scotia has to keep the mine's ventilation system running indefinitely to expel methane gas from the mine.

  • "A significant effect to noise levels is defined as a measurable local impact attributable to the Project that is identified through noise monitoring that exceeds regulatory requirements, or by repeated concerns expressed by area residents."

A request is made that responsible authorities ensure that measures are taken to mitigate any adverse noise levels presently being experienced by residents.

Endangered Wildlife

The Donkin Peninsula, in which the Donkin Mine is located, is part of the Northern Head / South Head Important Bird Area (IBA), including the Port Morien sandbar is one of the most bird-rich areas in Nova Scotia. Comparable to other well-known sites including Sable Island, Brier Island, Seal Island and Cape Sable Islands.

White Egret arrives from Florida
White Egret arrives from Florida

A total of thirty-seven bird species of conservation interest have been recorded from the Donkin Peninsula. "Northern Head supports a large seabird colony that is used by Black-legged Kittiwakes, Great Cormorants, Double-crested Cormorants, Razorbills, and Black Guillemots. Razorbill, Black-legged Kittiwake and Great Cormorant are listed as sensitive species by NSDNR."

Seabird Breeding Colony on North Head
Seabird Breeding Colony on North Head

Sensory disturbance to wildlife through noise emissions can potentially result in abandonment of nesting sites and changes in species populations over time, particularly for species of conservation concern. This is especially important during the breeding season from April 1 through to August 15.

The globally significant bird areas are endangered by an adverse change in their acoustic environment and the loss of habitat caused by clear-cutting the Donkin Peninsula of trees to make room for waste coal piles.

In Canada, under the federal Migratory Bird Convention Act, migratory birds, their young, eggs and nests are protected, prohibiting harassment of species.

The local bird areas are considered to be "globally significant” as a result of providing nesting, feeding and migratory habitat for approximately 300 bird species.

Bird habitat conservation is of the upmost importance. A request is made that responsible authorities ensure that measures are taken to mitigate any negative environmental effects experienced by wildlife.

WHERE WE ARE NOW

No jobs. No economic development. Community and wildlife health at risk. A global environmental legacy that also endangers our children's future quality of life.

Public discourse and political action is warranted.

POLITICAL ACTION

The Donkin mine approval decision statement of The Honourable Peter Kent, Minister of the Environment and Climate Change, dated July 12, 2013 was based on the implementation of the following required mitigation measures for:

  1. Greenhouse gas emissions

  2. Acoustic environment

  3. Wildlife habitat, including migratory birds

The Minister also requested that responsible authorities implement a follow-up program in order to determine the effectiveness of the measures taken to mitigate any adverse environmental effects of the Donkin mine.

In summary, as documented above, the Donkin Mine has caused significant adverse environmental effects because the appropriate mitigation measures have not been implemented as required by the Minister of the Environment and Climate Change.

  • "First and foremost, the health, safety, and well-being of all Canadians are top priorities for the Government of Canada." The Honourable Jonathan Wilkinson, May 22, 2020.

We respectfully call upon the the Minister of Environment and Climate Change, The Honourable Jonathan Wilkinson to request a follow-up mitigation measures program to solve the adverse environmental effects created by the Donkin mine.

References
May 2020

  • To view the full Canadian federal Minister decision and related documents, please visit the Impact Assessment Agency of Canada website here.

  • To view the full Nova Scotia provincial Minister decision and related terms and conditions, please visit the Nova Scotia Department of Environment website here.

  • Canadian Environmental Assessment Agency. April 2013. Comprehensive Study Report. Donkin Export Coking Coal Project

  • CBCL Consulting Engineers. October 2008. Donkin Underground Exploration Volume One Environmental Assessment Report.

  • Donkin Mine Project Supported by Stephen McNeil. January 7, 2016. CBC News Online.

  • Fisheries and Oceans Canada and Transport Canada. July 12, 2013. Decision.

  • Florida Museum of Natural History, 2018. Noise Pollution causes Chronic Stress in Birds, with Health Consequences for Young. Online.

  • Hansjoerg P. Kunc and Rouven Schmidt. November 2019. The Effects of Anthropogenic Noise on Animals: a meta-analysis.

  • Health Canada. 2010. Useful Information for Environmental Assessments.

  • Minister of Environment and Climate Change. May 22, 2020. International Day for Biological Diversity Statement.

  • Intergovernmental Panel on Climate Change. 2014. Climate Change Synthesis Report.

  • Marston Technical Report. November 2012. Donkin Coal Project.

  • Minister of the Environment. July 12, 2013. Decision Statement.

  • NSE - Nova Scotia Environment. Oct. 9, 2019, January 31, 2020 and May 6, 2020. Correspondence with Compliance Office.

  • Nova Scotia Environment. August 8, 2017. Minister's Approval.

  • Nova Scotia Department of Environment. 1989. Guideline for Environmental Noise Measurement and Assessment.

  • Per Facie Evidence. 2019 & 2020. Audio Recordings of Donkin Mine Noise are Available.

  • World Health Organization (WHO). 1995. Community Noise.

  • XSTRATA Coal Limited. July 2012. Environmental Impact Statement for the Donkin Export Coking Coal Project.