Public Comment: NWP Crown Mountain Coking Coal Project

I am writing to express my concerns following review of the NWP Coal Canada Ltd. (NWP) Crown Mountain Coking Coal Project (the Project) Environmental Impact Assessment (EIA) and associated Executive Summary.

Project Footprint and Access

• The Project’s footprint will directly impact between 851-1280 hectares (ha). According to the Terrestrial Ecosystem Mapping 71.47% (916.97 ha) of the Project footprint is on land with or capable of producing Old Growth and Mature Forest with all being cleared over the Project’s life, removing Species at Risk (e.g., whitebark pine) and wildlife habitat.
• There is mention that new conservation lands will be established (E.7.14.3) with no further detail or rationale as to how these will function as an offset for disturbance to existing conservation lands or a commitment to establishing these new lands close to the Project’s impact.
• Increased traffic along the upgraded Grave Creek and Harmer Creek Roads will also be detrimental. Grave Prairie is an important conservation area for wildlife (e.g., overwintering elk) and for recreation users. The EIA acknowledges that temporary disruptions to access will occur during the Construction and Pre-Production phases of the Project but fail to recognize that these disruptions will undeniably continue through the life of the Project. Even if access is maintained during the Project’s lifespan, constraints on use (e.g., road construction, blasting, heavy and light vehicle traffic) will assuredly reduce desirability of the area and reduce access recreational use over the entire Project lifespan.

Wildlife and Wildlife Habitat

• The short- and long-term (residual) impacts to wildlife are understated with no significant residual effects expected for all six valued components (VCs) (ungulates, carnivores, bats, birds, amphibians, Gilette’s Checkerspot), this seems highly unlikely given NWP’s own criteria, “Any effect then that diminishes the ability of a wildlife population to be persistent and self-sustaining were therefore used as a threshold for the determination of significant for residual effect.” (15.4.3.1). This ability is diminishes by restricting movement and increasing likelihood of incidental take from vehicle collisions.
• Similarly, the decline in “abundance or change in distribution” (15.4.3.1) also constitutes a significant adverse residual environmental effect. Sixteen years of 24-hour vehicle traffic, coal conveyor use, and general mining activity will change the distribution of species beyond the Project’s operational lifespan.
• Generic mitigations, management plans, and proposed reclamation to not fully address the impacts to the VCs and other wildlife over the Project’s life. For example, what methodology would be used for pre-clearing bat roost surveys? Are ultrasonic detectors going to be deployed at every suitable tree during the roosting window to detect presence? Is non-detection during the few nights of survey effort sufficient to proceed with clearing?
• The increased heavy and light vehicle traffic will impact wildlife via sensory disturbance and potential for negative human-wildlife interactions (e.g., collisions). Sixteen years of constant traffic must have an impact on this important movement corridor and that the assumption that following reclamation this will resolve itself when multiple generations of species have avoided it is questionable.
• The lack of confidence in the conveyor and road mitigation (E.7.10.4.1) is also concerning considering the necessity of these and the large linear impacts. If these mitigations are data deficient, why aren’t additional studies being commissioned prior to Project application? Given the length of the disturbance and the area’s use as a wildlife movement corridor more effort should be put in to justify upgrading and adding linear disturbance. As well, given the length of the conveyor, only including two underpasses per 1,000 metres seems limiting to wildlife movement. What data supports the spacing of underpasses?

Water Treatment and Quality

• The entire Project relies on use of the layer cake method which has not been proven effective. In a previous news release (https://elkvalleycoal.com/crown-mountain-project-updates/), NWP suggested a pilot mine rock storage facility prior to mining to understand the effectiveness of selenium sequestration using the layer cake method. Nowhere in the EIA is a pilot studied mentioned and materials on the NWP website (https://nwpcoal.com/environmental/) indicate that only conceptual studies were undertaken by Enviromin and surface water modelling by SRK. This work was buried in Appendix 3-C of the EIA. There is no mention of these conceptual studies in the Executive Summary. If these are the basis for use of the method and provide justification, why are they not highlighted? Enviromin concluded that “microbes in both the coal reject from Crown Mountain coal and the waste material collected at Sekunka are capable of nitrate and selenium removal…” and that Sekunka rock was used as a proxy for waste rock at Crown Mountain. These data were provided to NWP for “use in modeling and design of pilot and full-scale mine rock disposal facilities”. Again, no mention of a pilot and the language of the report suggest that the technology is capable but at what removal levels and it has not been tested in the field.
• The Project should not be approved on purely conceptual and untested waste rock management that is deemed “capable” with the hope that it will work and not further degrade the surface and groundwater of the region. What happens when it fails or does not meet established compliance thresholds? NWP has said they are not considering active water treatment. If it is required, would they have the funds to implement it, or does the area deal with a lifetime of non-compliances?

Community and Housing

• As someone who lives in Sparwood and is very aware of the housing crisis we are facing, NWP “intend to capture local labour force”, but “participation” and “monitoring” of community programs and housing availability will do little to alleviate the influx of temporary workers who will inevitably be required (E.7.13.2). Intention isn’t going to house these people and their families and there are no concrete commitments to invest in the community and alleviate the stresses this Project will create.

While I understand the importance of economic development, the EIA still leaves substantial uncertainty and little justification for the direct and indirect impacts to a high-value environmental and recreational area, all for a Project with a short 16-year lifespan. Short-term profit should not take precedence over environmental health. I do not feel this Project is in the best interest of the Elk Valley community and more importantly the local environment.