Coal Mining in the Rockies
Response from Minister Wilkinson on Montem Application (here)
Montem Resources $5 million application to Clean Energy Fund (here)
SAGE submission to IAA re: Tent Mountain Coal project (here)
Alberta Coal Policy: What’s the hurry? (here)
Support for Regional Assessment of Coal Development and Exploration Activity in Southwest Alberta (here)
SAGE submission to the Coal Policy Committee (here)
G7 Climate and Environment: Ministers’ Communiqué (here)
Getting Serious About Global Warming and Climate Change (here)
Time to Step Up and Protect Our Water (here)
Metallurgical Coal – What is it good for …? (here)
Terms of Reference: Alberta Coal Policy (here)
Parks, Recreation and Coal Mining (here)
Coal Mining in the Oldman River Headwaters & Water Abstraction (here)
Coal, Calcite and Cutthroats (here)
Selenium's Impact on the Environment (here)
Is Mountain Top Coal Mining in the Oldman Headwaters Worth the Risk? (here)
January 28, 2022
The Honourable Jonathan Wilkinson,
Minister of Natural Resources,
House of Commons,
Ottawa, Ontario K1A 0A6
Re: Montem Resources: Application to the Federal Clean Fuels Fund
The Southern Alberta Group for the Environment (SAGE) is concerned about Montem Resources’ application for a grant of up to $5 million from the Clean Fuels Fund to help finance feasibility studies into the concept of building a 320 MW pumped hydro energy storage with the potential for hydrogen production. Our concern is based on three main principles: 1) that ‘clean fuels’ research and development should be explored by corporations committed to fossil fuel reduction; 2) that government support for feasibility studies of this sort should be evaluated with a systems approach and under the purview of the provincial electricity system operators (that is, the project results in a reduction of greenhouse gas emissions for the system); 3) that the proposal should pass some cursory feasibility evaluation before funding of this magnitude.
Montem Resources’ Tent Mountain Mine Redevelopment Project has been designated for an assessment under the Impact Assessment Act of Canada. As argued by SAGE in its submission opposing this development, continuing to support coal mining for thermal or metallurgical use is contradictory to Canadian commitments of reducing greenhouse gas emissions to achieve net-zero by 2050. As a minimum, this coal mining project application should be withdrawn by Montem prior to its application for funds to conduct a feasibility study for ‘green energy’ land use.
The concept of pumped hydro, from an environmental perspective, is to shift electricity supply from low-demand times to high-demand times. In other words, the customary incentive of pumped hydro is to store energy produced when supply exceeds demand and use this energy to help lower peak demands which requires expensive, and often lower efficiency, electricity generation. Pumped hydro is an energy storage scheme that has an energy-cost of 20 to 30%, based on the difference between the electricity consumed to pump the water to the higher elevation and the electricity produced by the system when the water flows to a lower elevation. It is always better to use the electricity when it is available (so as the energy-cost can be avoided). Any feasibility study that will benefit the environment by reducing emissions should be conducted considering the dynamics of the whole electricity system and, arguably, by the electricity system operator for the province. It should also consider emerging demand management opportunities such as charging electric vehicles during low-demand periods – thus balancing demand with supply and greatly reducing the need for such storage schemes.
The final principle for funding such a project would be that it makes some cursory sense. If hydrogen production is a component of this project, one might ask why the hydrogen cannot be produced directly (without the energy-cost of pumped hydro) at the time of low-demand electricity generation. That is, if renewable energy technologies are producing energy at low-demand times, why can’t hydrogen be produced without the need for pumped-hydro? What is the energy-cost of compressing and transporting hydrogen from this location on the border of Alberta and British Columbia? Clearly, if hydrogen is being produced for export or industrial use, would it not be better to situate the process closer to the end-user and reduce transportation losses and associated emissions? In a province like British Columbia that is currently completing the Site C dam, would it not be more efficient to include pumped hydro at a much larger scale at this location? We would hope that any consideration of funding a feasibility study would involve some expert evaluation of the basic merits of the project.
In summary, SAGE is concerned that investing $5 million into a feasibility study to assess the need for pumped hydro and a hydrogen-producing process would not be the best use of public funds. Any such proposal requires a thorough systems approach of analysis. It is particularly of concern that the applicant maintains their interests in coal mining along the eastern slopes of Alberta while, incongruously, presenting an interest in renewable energy.
cc: Hon. Steven Guilbeault, Minister of Environment and Climate Change
Response from Minister Wilkinson ... here
Sent to the Impact Assessment Agency of Canada, 8 December 2021:
RE: Comment on Montem Resources’ Tent Mountain Redevelopment Project
The Southern Alberta Group for the Environment (SAGE) requests that the Impact Assessment Agency of Canada establish a Joint Review Panel to evaluate the environmental impacts of the proposed Tent Mountain Redevelopment Project.
An environmental impact assessment on the Tent Mountain Project should consider the following:
- The potential impact on species at risk, including the Westslope Cutthroat Trout, designated as Threatened in Schedule 1 of the federal Species at Risk Act. The grizzly bear is a species of special concern under Part 4 of the Species at Risk Act; and the Whitebark pine is listed as an Endangered Species under Part 2 of the Species at Risk Act. Consideration should also be given to the federal Fisheries Act that states its purpose to include “the conservation and protection of fish and fish habitat, including by preventing pollution” (2.1b). The Tent Mountain Project may adversely impact these species in this ecologically important region of the Crown of the Continent in southern Alberta.
- Since the Tent Mountain mine stopped operations in 1983, there has been a growing body of scientific knowledge related to cumulative effects, water pollution, air pollution and the ecological impacts of industrial activities. Due to the lengthy interregnum in coal production, this science should be reviewed and considered in the assessment process. An effective process might include a Joint Review Panel similar to the one conducted for the Grassy Mountain Coal project. The science presented in this process should consider the findings and decisions against the Grassy Mountain Coal project, and the existing environmental impacts from similar mining operations in southeastern British Columbia.
- Due to the serious risk of contaminants (including selenium) to downstream water systems from surface removal of coal, it is strongly recommended that robust water monitoring systems be implemented and monitored to provide an accurate assessment of water quality and concentration of contaminants considering seasonal variations, longitudinal variations between years, and to establish a baseline of pollution from legacy mining operations. As a recent Golder report (State-of-Knowledge on Selenium Treatment Technologies, 2020) has stated: “Despite numerous installations, selenium treatment technologies have not reached full maturity and should still be regarded as developmental.” Widespread selenium contamination of the rivers downstream of Teck Resources operations in southeastern British Columbia and downstream of Hinton, Alberta should instill caution in overestimating the capability of treating selenium once released to the environment.
- The shared federal-provincial responsibilities in water governance includes managing water for ‘agriculture, significant national water issues, and health’. In addition, the Master Agreement on Apportionment (MAA) is designed to ensure the sharing of both quantity and quality of water between prairie provinces. With the effects of climate change manifested by declining river flows (and exacerbated by over-allocation of water for irrigation and intensive livestock operations), water pollution from additional industrial activity can be viewed as a serious threat to the health of the ecosystem and the regional economy that depends the abundance and availability of uncontaminated water.
- The Constitution Act of 1982 and decisions by the Supreme Court of Canada have directed that there is a ‘Duty to Consult’ First Nations on projects that adversely affect their ability to practice Aboriginal and Treaty rights in the region, which is under federal jurisdiction.
- Finally, we believe that there is an obligation to act on global climate change by honouring our commitments made at UNFCCC conferences. As such Canada must act in accordance to reports from the UN Environmental Programme (UNEP) that advocate for all nations to cease new investment in coal extraction, and to plan for the decommissioning of existing operations, in global efforts to limit global warming and moderate the climate crisis. There is a global consensus on coal that, put bluntly, says: if we don’t dig it up, it won’t get burned.
SAGE supports the decision by the federal Minister of Environment and Climate Change to designate this project for environmental assessment. We look forward to your decision.
Alberta Coal Policy: What’s the hurry?
Published in The Lethbridge Herald (here)
19 June 2021
The UPC government has created a committee to make recommendations towards a new Coal Policy for Alberta. This committee is expected to complete their evaluations by November this year. Considering that it took four years for the government of Peter Lougheed to develop the 1976 Coal Policy, and that Steve Allan’s inquiry has been allowed at least two years to investigate ‘unAlbertan activities’, it seems absurd that something as complex as a modern Coal Policy can be completed by autumn.
And what’s the hurry? If they intend to do a good job, the committee has much to consider.
First, the main arguments for opening up the Eastern Slopes of the Rocky Mountains are jobs and royalties. Yet, there has been no evaluation of the net benefits of coal mining: How many jobs created and how many jobs lost in other industries? How many jobs foregone in the future, if our water becomes contaminated? What are the expected royalties, given current revenues don’t even cover the annual cost of the War Room? What are the economic liabilities for human health, loss of biodiversity, or diminishing ecosystem services?
Second, will the Coal Policy Committee be considering the fair allocation of water among competing users in the headwaters of the Oldman River basin? Will there be a considered evaluation of the contamination of water in the headwaters which may impact fish and wildlife habitat as it already has downstream of the three coal mines near Hinton? Interestingly, recent research suggests that selenium contamination and sodium absorption ratios (SARs) in rivers downstream of these mines are reaching levels unsafe for use as irrigation water. With declining river flows and increasing concentrations of pollutants, could that happen in the Oldman River basin? And consider that recent research suggests that waste rock dumped from surface mining operations may leach contaminants for decades, and even centuries. Who will take responsibility for such long-term liabilities? Historically, Alberta governments have passed much of this responsibility on to the taxpayer and to the natural environment.
Third, will the Coal Policy Committee reflect on the recent conclusions of the International Energy Agency that “No new coal mines or extensions of existing ones are needed […] as coal demand declines precipitously. Demand for coking coal falls at a slightly slower rate than for steam coal, but existing sources of production are sufficient to cover demand through to 2050.” If this coal is not needed why would Albertans risk future economic opportunities in the tourism and recreation sector, and the viability of the $3.6 billion a year agri-food sector downstream? Why would Albertans risk the health of our environment and quality of our water for the short-term profits of foreign corporations?
Designing a Coal Policy is complex. It involves present and future uses of the Eastern Slopes. It involves jobs today and jobs tomorrow. It involves the health of our natural environment. And without exaggeration, it involves the future quality of life in southern Alberta. There are a lot of questions. What’s the hurry in ramming through new policy without carefully considered answers to these questions?
SAGE is a leading voice for a healthy and sustainable community. For our submission to the Coal Policy Committee, visit sage-environment.org. You may send your own thoughts to the Coal Policy Committee at email@example.com
 Contaminant from Coal Mines Already High in Some Alberta Rivers. CBC (Jan 25, 2021) https://www.cbc.ca/news/canada/edmonton/selenium-alberta-coal-mines-contamination-1.5886293
 Achieving Net-Zero Emissions by 2050. International Energy Agency. https://www.iea.org/reports/world-energy-outlook-2020/achieving-net-zero-emissions-by-2050
Hon. Jonathan Wilkinson
Minister, Environment and Climate Change Canada
Dear Minister Wilkinson,
Re: Support for Regional Assessment of Coal Development and Exploration Activity in Southwest Alberta
Since 1984, Southern Alberta Group for Environment, based in Lethbridge AB, has been a leading voice for a healthy and environmentally sustainable community. For the last year we have been informing ourselves and others in our community about proposed coal mines in the Oldman River headwaters and advocating for rigorous environmental assessment, including cumulative effects assessment. Assessment of the impacts of coal development in our headwaters cannot be dealt with appropriately on a project-by-project basis, nor should it be solely within the purview of our provincial government given arbitrary rescission of the 1976 provincial Coal Policy and all the aspects of federal jurisdiction that are affected.
We are writing to express our support for the submission by Ecojustice (28 May, 2021) on behalf of Niitsitapi Water Protectors, Canadian Parks and Wilderness Society Southern Alberta Chapter and Livingstone Landowners Group to the Impact Assessment Agency of Canada requesting the Agency recommend “a committee of independent experts to conduct a regional assessment of the potential adverse effects of existing or future metallurgical coal mining activities that fall within federal jurisdiction over a geographical region that includes the Rocky Mountains and the Eastern Slopes of southwest Alberta and the Elk Valley of southeast British Columbia, and include an analysis of different scenarios regarding the pace and scale of future development of metallurgical coal mining in the region and an analysis the future global market for metallurgical coal”.
Areas of federal jurisdiction include impacts on fish and fish habitat, impacts on critical habitat of species at risk (whitebark pine, limber pine, grizzly bear), impacts on exercising of rights by First Nations and Indigenous peoples, impacts on greenhouse gas emissions and fugitive methane emissions, and transboundary impacts.
You may wish to order a 45-day extension of time to allow more complete gathering of information prior to making your decision.
I appreciate your consideration of this request.
SAGE submission to the Coal Policy Committee
June 9, 2021
May 30, 2021
To: The Honourable Johnathan Wilkinson
Minister of Environment and Climate Change
From: Braum Barber
Southern Alberta Group for the Environment
Re: G7 Climate and Environment: Ministers’ Communiqué
The Southern Alberta Group of the Environment supports and appreciates the bold action by G7 nations to honour their commitments to address the many and related impacts of climate change.
We are particularly supportive of the policy direction regarding new coal production and dramatically reducing coal-related emissions. From the Communiqué:
“Consistent with this overall approach and recognising that continued global investment in unabated coal power generation is incompatible with keeping 1.5°C within reach, we stress that international investments in unabated coal must stop now and commit to take concrete steps towards an absolute end to new direct government support for unabated international thermal coal power generation by the end of 2021, including through Official Development Assistance, export finance, investment, and financial and trade promotion support. We commit to reviewing our official trade, export and development finance policies towards these objectives.”
SAGE is encouraged by the promise of the Canadian government to set targets for net-zero emissions by 2050 and reconciling national emissions with trade policies, and hope that this will include agreements to reduce ‘leakage’ of carbon emissions via our global trade in fossil fuels.
We are moreover hopeful that ‘an absolute end to new direct government support’ of coal power generation will also include an absolute end of approvals for new coal mines along Alberta’s Eastern Slopes, whether for thermal or metallurgical end-uses. The International Energy Agency report released concomitant with the G7 Ministers’ Communiqué has clearly stated that: “No new coal mines or extensions of existing ones are needed in the NZE as coal demand declines precipitously. Demand for coking coal falls at a slightly slower rate than for steam coal, but existing sources of production are sufficient to cover demand through to 2050” (p.103).
We look forward to progress towards achieving these important aspirations.
Time to Step Up and Protect Our Water
Published in The Lethbridge Herald
28 April 2021
The government of Peter Lougheed implemented the Coal Policy after substantial consultation and expert review over a period of four years. They decided to restrict coal development in the mountains. Their conclusion was that the Eastern Slopes were vital to the economy and the well-being of human population because this region was the primary source of clean water for the province.
Minister Nixon assures Albertans [Government Will Continue to Protect Alberta’s Water, Lethbridge Herald, April 17, 2021] that the water is being protected and that the rules remain unchanged. This assurance is difficult to reconcile with the numbers. The Oldman Allocation Order (Section 3) provides that an allocation may only be made for one of seven purposes (municipal, commercial, recreation, community water supply, agriculture, irrigation and industrial purposes). Allocations of water for industrial purposes must not exceed 150 acre-feet, per this order.
For context, let’s remember that this government negotiated with Australian coal mining corporations (seemingly outside of public enquiry) and rescinded the 1976 Coal Policy without notice and without consultation with Albertans. They then opened the Eastern Slopes to coal leases and immediately permitted temporary licenses for removal of water (outside of the allowed allocation) for exploration. After massive expressions of public outrage, they reinstated the Coal Policy … well, except for the already leased lands and without addressing the Grassy Mountain and Tent Mountain coal mining projects already put in process. There appears to be no cost-benefit or net-jobs analysis for this fixation on coal mining.
For the Grassy Mountain project alone, Benga Mining Limited has applied for the total 150 acre-feet allowed in the Oldman Allocation Order. In addition, they have requested 100 acre-feet to be transferred permanently from a water license held by Devon Canada (diverted from the Crowsnest River) and 200 acre-feet transferred temporarily for 25 years from a license for municipal purposes held by Blairmore (diverted from York Creek). This is for only the one mine. Where will the water come from for mining the leases that have already been sold? What will the impact be on all of these small creeks when large volumes of water are removed? Is this what Minister Nixon was saying?
The UCP government has promised Albertans a consultation process for a new Coal Policy. The Terms of Reference for this consultation does not include water allocation. It also does not include a discussion on potential water contamination (like selenium, arsenic or calcite). It does not include a discussion on parks and other recreational uses on public land, and it does not include a discussion on future economies based on tourism (assuming there are tourists interested in industrial landscapes). The UCP government wants this process done by the end of the year – which is nothing like the robust process used by Premier Lougheed. Does this sound like protecting anything (except coal mining)?
So, you can see nothing has changed. The UCP government is driven to divert public attention using a faux-consultation while they continue to entrench coal mining along the Eastern Slopes. There are no apparent plans for protecting the quality or quantity of water needed by Albertans and an agriculture-based economy. All this cheap land and free water to mine coal for a 1% royalty. And all this without a risk analysis for lost jobs and other costs in the downstream economy. It brings to mind the adage about selling one’s birthright for a mess of pottage.
It is time, Lethbridge, to step up and protect our water.
Metallurgical Coal – What is it good for …?
Published in The Lethbridge Herald
24 March 2021
The eastern slopes region of Alberta is the source of the headwaters providing fresh water for wildlife and prairie communities living downstream. It has been a highly desirable destination for tourism and year-round recreational activities like camping, hiking and skiing, attracting residents and revenue. Despite vague assurances from the UCP government, allowing coal mining along the eastern slopes is still very much under consideration.
We have become more aware of the environmental impacts of mountaintop removal methods of coal extraction –risk to endangered wildlife, noise, air pollution and water pollution – but we haven’t heard much about greenhouse gas emissions. There is the perception being circulated that ‘metallurgical’ coal is somehow different and less damaging to the environment compared to ‘thermal’ coal. This is not the case. Coal is classified from high-carbon anthracite, to bituminous, to subbituminous, to lower carbon lignite. The final application (steel making, cement making, electricity generation, etc.) of coal depends on process requirements and economics. Steel making has traditionally used the higher-grade bituminous coal which is further processed into a porous mass with fewer impurities – this is called coking coal. In the end, however, the coal is burned and emissions are generated.
The dominant method of making steel is the blast furnace/basic oxygen furnace process. Coking coal is used to reduce iron ore in a blast furnace to make pig iron. The carbon remaining in the pig iron is then burned off using oxygen to make steel. For each tonne of steel about 770 kg of metallurgical coal is consumed, resulting in 1.73 tonnes of carbon dioxide emitted to the atmosphere. Worldwide, this amounts to over 2 billion tonnes of CO2 emitted for steel making each year. This sector is the second highest emitter of greenhouse gases in the world (after concrete making).
The Grassy Mountain Coal project alone (and there may be others) is expected to produce 4.5 million tonnes of coal each year for the next twenty-five years. This mine will ultimately contribute roughly 8 million tonnes of CO2 emissions each year – equivalent to almost 2 million cars. Opening up Alberta for coal mining is incongruous with global efforts to achieve net-zero greenhouse gas emissions within thirty years (let alone reducing emissions by 40% by the end of this decade). The UN Environmental Programme has recently stated that coal use must be phased out in all sectors to moderate the emerging climate crisis.
Are there alternatives? Yes. Though steel is a highly recycled material, still over 20% of it ends up in the landfill. Recycled steel contributes considerably fewer emissions. Also, new technologies for steel making are replacing metallurgical coal with hydrogen as a fuel. It still takes energy to make hydrogen, but it is cleaner to use overall than metallurgical coal. Using traditional electricity sources to make hydrogen, emission reductions of 20 to 30 percent are immediately achievable. Using renewable energy technologies to produce hydrogen for steelmaking can potentially reduce emissions by 80%. These technologies are operating in pilot phases in German, Sweden and Finland.
With the world turning its attention to meeting reduction targets in greenhouse gas emissions, it is an inauspicious time to begin to open up our eastern slopes to coal mining. The steelmaking industry is directing its attention to reducing its emissions by using new technologies that no longer rely on metallurgical coal. This is yet another reason it is not the time for Alberta to engage in coal exploitation. Alberta needs a future-oriented economy.
The Southern Alberta Group for the Environment is a leading voice for a healthy and environmentally sustainable community. For more information, visit our site at sage-environment.org
Albanese says we can’t replace steelmaking coal. But we already have green alternatives.
Fact Sheet Steelmaking Coal: Teck Resources PDF
Report on Annual Worldwide Carbon Dioxide Emissions from Blast Furnace
Iron Ore Smelting and Coke-making
A Tale of Two Coals
Grassy Mountain Coal Project
29 November 2019: Climate and Environment
World Steel Recycling Figures 2015 – 2019
World Steel Recycling Figures 2015 – 2019
H2 @ Scale Workshop: D of Energy
H2 @ Scale Workshop PDF
Hydrogen as a Clean Alternative in the Iron and Steel Industry
Hydrogen as a Clean Alternative in the Iron and Steel Industry
Greenhouse Gas Emissions from a Typical Passenger Vehicle
Greenhouse Gas Emissions from a Typical Passenger Vehicle
March 25, 2021
To: Hon. Sonya Savage, Minister of Energy
Hon. Jason Nixon, Minister of Environment and Parks
Cc: Nathan Neudorf, MLA Lethbridge-East
Shannon Phillips, MLA Lethbridge-West
Re: Terms of Reference for Public Consultation on Alberta Coal Policy
The Southern Alberta Group for the Environment (SAGE) appreciates the decision of the Government of Alberta to conduct public consultations on the Coal Policy. Though there have been a range of interpretations presented in the media, it is our understanding that the consultations will thoroughly evaluate options for a future coal policy, including ‘no-coal’ mining on the eastern slopes of the Rocky Mountains and our collective headwaters.
As the Coal Policy public consultation date approaches, SAGE would like to offer some thoughts regarding the Terms of Reference:
- That the terms of reference be expansive in nature and reflect the values of Albertans, including maintaining ecological integrity of the headwaters, establishing best-use of water in the region including instream flow needs, and identifying and realizing recreation and tourism opportunities. Foremost, a ‘no-coal’ policy for Alberta should be evaluated.
- All coal mining proposals currently in process and exploration on leases should be suspended indefinitely until the completion of a public consultation and the passing of new legislation.
- A coal policy should reflect the objectives of current legislation including the federal Impact Assessment Act, Fisheries Act and Species At Risk Act and the provincial Environmental Protection and Enhancement Act, Water Act, Alberta Land Stewardship Act, Wildlife Act and Irrigation Districts Act as well as a variety of approved plans and policies including the South Saskatchewan River Basin Water Management Plan, the South Saskatchewan Regional Plan and the Alberta Wetland Policy.
- A land footprint management plan should be expanded to encompass the eastern slopes. Land footprint management planning, such as is found in the Livingstone-Porcupine Hills Land Footprint Management Plan approved in May 2018, provides a science-based approach to managing human footprint (linear and spatial) to sustain those aspects of the Eastern Slopes that Albertans clearly identify as a priority – headwaters, westslope cutthroat trout, Foothills fescue grasslands, recreation opportunities and high scenic values. We encourage the Alberta Government to implement that plan and to use it as a model for other subregional plans in accordance with the Alberta Land Stewardship Act. Current exploration for coal in the Livingstone-Porcupine Hills violates the limits and thresholds of the land footprint management plan. A coal policy must be consistent with subregional plans.
- As discussed in the South Saskatchewan Regional Plan (SSRP), A Policy for Resource Management of the Eastern Slopes (“Eastern Slopes Policy”), “provides the foundation for the province’s Integrated Resource Plans at subregional and local levels within the eastern slopes and sets watershed management as the highest priority in the overall management of the eastern slopes. The natural resources are to be developed, managed and protected in a manner consistent with principles of conservation and environmental protection.” The Integrated Resource Plans for the region should be reviewed for their relevance and revised to include: current science on cumulative environmental impacts; economic principles that consider ecological values of wildlife habitat; values related to intensified demand for wilderness recreation and tourism; and the ‘internalizing’ of social and environmental costs of water pollution and climate change in decision making.
- A coal policy should clearly define all of the terms used to describe the extraction techniques of coal mining, including mountaintop removal, open pit, strip mining, etc.
- There should be clear delineation of the precautionary principle vs. adaptive management. A coal policy should establish environmental thresholds for monitoring and any enforcement or additional measures to be applied when critical thresholds are being approached or exceeded. Per the precautionary principle, unproven processes should not be implemented at full scale until adequately piloted, and there should be a willingness to terminate coal production to protect the ecosystem and other economic interests from further impact.
- A coal policy should be dedicated to improving our knowledge and understanding of surface and groundwater flow and aquatic and riparian ecosystems. Current science to establish instream flow needs (IFN) based on fish habitat, water quality, riparian vegetation, channel maintenance, etc. should be applied. Mechanisms for suspending industrial production when minimum flows are threatened should be clearly defined.
- A coal policy must review the Oldman River Basin Water Allocation Order and water licensing and transfer mechanisms in the basin to align with long-term societal goals and provide predictability in water availability. The water allocation process should reflect the current situation of over-allocation in the basin, as well as the impacts of climate change on future water availability. Conservation of water use through technological advances and efficiencies should include allocations to benefit aquatic ecosystems.
- A coal policy should incorporate restoration and reclamation management that sustains biodiversity and watershed integrity. Strategies to achieve this are provided in the Livingstone-Porcupine Hills Land Footprint Management Plan. Corporations should provide proof of secure and sufficient funds (such as a trust or Surety Bond) to cover the full costs of operating impacts due to tailing pond breaches and other catastrophic failures of production, as well as end-of-project abandonment and reclamation costs.
The Terms of Reference for the public consultation of a new Coal Policy should express the complexity of integrating existing policies and plans and include the greater scientific understanding and ecological and social concerns that have emerged since the last policy was created 45 years ago, including water allocation, cumulative effects, linear disturbance, ecological integrity and climate change. Albertans have also learned the lessons of failing to account for the ecological and social liabilities incurred from resource extraction – costs that are now being borne by the taxpayer. A new Coal Policy must be a better coal policy.
Given these concerns, SAGE believes that a no-coal option is an opportunity for the UCP government.
World governments are taking the last thirty-five years of accumulated climate science and empirical evidence seriously, and are beginning to act to reduce net greenhouse gas emissions by 40% by the end of this decade and by over 80% by 2050. The UN Secretary-General, António Guterres, has recently called on all nations to end subsidies for fossil fuels and ‘kick the coal habit’ to limit global annual warming to below 1.5°C. There is a growing consensus that coal will be the first fossil fuel that will be left in the ground.
If governments do in fact respond to this existential threat, there will be a near-term diminishing demand for coal – for thermal, metallurgical and other uses. It is not an opportune time to re-open the province to coal mining. It is, however, an opportune time to boldly end coal mining in the province. As the last of the coal-fired electricity generation facilities are retired by 2023, the province can accumulate some social license in regards to tourism and international trade by declaring Alberta coal-free. In the long term, our eastern slopes are more valuable as a desirable wilderness destination for recreation and tourism, and as a source of clean, safe water for downstream users including our multibillion-dollar agricultural industry.
The UCP government might consider collaborating with the NDP to develop non-partisan legislation to ban coal mining in Alberta and protect the future for Albertans.
March 16, 2021
To: The Honourable Jonathan Wilkinson, Minister of Environment and Climate Change
RE: Federal Review of Montem Resources’ Tent Mountain Project
The Southern Alberta Group for the Environment (SAGE) requests that the Minister of Environment and Climate Change designate Montem Resources’ Tent Mountain Project for an impact assessment under section 9(1) of the Impact Assessment Act, SC 2019, c28, s1.
The Tent Mountain Project should be designated for a federal review because:
- The designed production rate for the production is 4,925 raw tonnes per day, which is only 1.5% short of the 5,000 tonnes per day threshold set out in s.18(a) of the Physical Activities Regulations, SOR/2019-285. Since this is a doubling of the production rate compared to the previous operator in 1983, it is our perspective that the projected production rate of 4,925 raw tonnes per day meets the spirit of the Physical Activities Regulations.
- The potential impact on species at risk, including the Westslope Cutthroat Trout, designated as Threatened in Schedule 1 of the federal Species at Risk Act. The grizzly bear is a species of special concern under Part 4 of the Species at Risk Act; and the Whitebark pine is listed as an Endangered Species under Part 2 of the Species at Risk Act. This project may adversely impact these species and others in this ecologically important region of the Crown of the Continent in southern Alberta.
- It should be acknowledged that since the mine stopped operations in 1983 there has been a growing body of scientific knowledge related to cumulative effects, water pollution, air pollution and the ecological impacts of industrial activities. Due to the lengthy interregnum in coal production, this science should be reviewed and considered in the approval process. A similar process for the Grassy Mountain Coal Project is currently being conducted by a Joint Review Panel. The science presented in this process should apply to Montem Resources’ Tent Mountain Project, particularly as it relates to the cumulative effects of allowing these projects and other mountaintop coal removal leases approved in the region.
- Similarly, the Constitution Act of 1982 and decisions by the Supreme Court of Canada have directed that there is a ‘Duty to Consult’ First Nations on projects that adversely affect their ability to practice Aboriginal and Treaty rights in the region, which is under federal jurisdiction.
- SAGE has been a long-term advocate for the environment in the region that encompasses the Oldman River watershed. We are very concerned about the potential for water contamination from mountaintop removal coal projects in our headwaters. These waters sustain downstream communities and water-dependent industries from the mountains to Lake Winnipeg. It is important that there be greater federal evaluation and oversight of interprovincial waters: Saskatchewan and Manitoba should be considered important stakeholders given the risk of pollution.
- Finally, we believe that there is an obligation to act on global climate change and honour our commitments made at the Paris Accord, and respond to reports from the UN Environmental Programme (UNEP) that advocate for all nations to ‘kick the coal habit’ in global efforts to limit global warming and moderate the climate crisis.
SAGE understands that the Alberta Energy Regulator (AER) will require a provincial Environmental Impact Assessment for the Tent Mountain Project. We believe, however, that the long-term impacts to Canadian interests and the important aspects under federal jurisdiction, as discussed, should be considered by the Minister of Environment and Climate Change.
We look forward to your decision.
Response from Minister Wilkinson (Download here ...)
Parks, Recreation and Coal Mining
Published in The Lethbridge Herald
6 February 2021
The eastern slopes region of Alberta is recognized as important habitat and a migration corridor for wildlife ranging from Yellowstone to the Yukon. Roughly 53,000 square kilometers of this corridor has been opened to coal mining by the UCP government without public consultation, and seemingly without consideration.
This region is the source of the headwaters, it is an important carbon sink, and it preserves local biodiversity. It has also been a highly desirable destination for tourism and year-round recreational activities like camping, hiking and skiing, attracting residents and revenue. Can we have both coal mining and natural areas for wildlife and nature-based recreation?
The decision by the UCP government to open mountaintop removal operations for coal mining will destroy large areas of wilderness, including river valleys that represent remaining habitat for some species-at-risk. Extensive industrial traffic, noise and water pollution will impact wildlife habitat and human use for distances well outside of the coal mining operations, particularly downstream. In addition, continued coal extraction perpetuates reliance on the fossil fuels that contribute heavily to global greenhouse gas emissions.
Very large areas of public land are now open for coal exploration, and leases for coal mining operations have already been sold to foreign corporations for a pittance. It has been reported that one-third of the Oldman North provincial recreation area is covered by a coal lease with a proposed mine pit on the north border of the recreation area. Other popular recreation areas that are surrounded by coal leases include Livingstone Falls, Honeymoon Creek, Racehorse and Dutch Creek.
A recent research article titled, ‘Identifying key ecosystem service providing areas to inform national-scale conservation planning’ developed new methods that integrate measures of the capacity of ecosystems to provide services (like carbon storage, clean water and nature-based recreation) with indicators of human demand. The paper identified ‘ecosystem hotspots’ in Canada that ‘should be the focus of conservation actions.’ One hotspot identified was the British Columbia-Alberta border, based on wilderness recreation.
This report suggests that a complete management planning framework would include aspects like biodiversity and ecosystem functions and services (including the provision of freshwater but also flood mitigation and soil retention). Management planning would also respect cultural and social impacts of significant land-use changes like coal mining.
The UCP government has suddenly decided to open the eastern slopes to coal mining after 45 years of protection. Considering the long-term risks to our region and the economic development options that have been sacrificed, such as nature-based tourism, this decision demanded, at a minimum, robust public consultation, sound economic analysis, and careful scientific study. Albertans got none of this.
We encourage you to share your opinions on this topic with your MLAs. The Southern Alberta Group for the Environment is a leading voice for a healthy and environmentally sustainable community. For more information, visit our site at sage-environment.org
Mitchell, M.G.E. et.al. (2021). Identifying key ecosystem service providing areas to inform national-scale conservation planning. In Environmental Research Letters, Volume 16, Number 1. (https://iopscience.iop.org/article/10.1088/1748-9326/abc121)
December 14, 2020
To: Nathan Neudorf, MLA Lethbridge-East
cc: Shannon Phillips, MLA Lethbridge-West
Joint Review Panel: Grassy Lake Coal Mine
RE: Coal Mining in the Oldman River Headwaters & Water Abstraction
The Southern Alberta Group for the Environment (SAGE) is greatly disappointed with the UCP government’s unilateral decision to open another 2000 hectares of land in our headwaters for coal extraction. It defies comprehension that this lease offering would be advanced just after the public hearing on the Grassy Mountain Coal Project concluded and prior to the Joint Review Panel making its recommendations.
Proceedings of the Joint Review Panel hearing for the proposed Grassy Mountain Coal Mine include serious, deeply concerning issues regarding impacts on water and air quality, human health, adjacent residents and local communities, indigenous traditions, wildlife habitat and migration corridors, species-at-risk, a nascent ecosystem-based tourism industry, as well as the availability of water for the ecosystem and downstream users. There are lessons to be learned from over two dozen sound scientific studies in the Appalachians which found that mountaintop removal mining devastates ecosystems, pollutes water and air, and negatively impacts public health including statistically significant increases in rates of cardiovascular disease, kidney disease, chronic lung disease, cancer, birth defects and death.
The UCP government has recently indicated its intention to bypass established water transfer markets in the Oldman River Basin to make allocations freely available to coal companies. Bypassing established processes and expectations for water allocation and abstraction in order to expedite coal mining, without public consultation, undermines trust in fair dealings with the government. In economic terms, perceived unfairness and an additional degree of uncertainty in the equity of exchange practices increase transaction costs to industry.
The UCP machinations around water policy and allocation appear to be motivated by the proposed Grassy Mountain coal mining application: one wonders what this government has in mind to provide the required water for another 840 square kilometers of open-pit coal mining operations currently being offered? It raises questions on what other accommodations have been promised to potential bidders, which may do more to inflame rather than reduce the existing climate of concern and uncertainty about coal mining in our headwaters. As with the decision to rescind the coal policy it shows a flagrant disregard for public opinion, due consultation processes and outcomes of regional land use and water management planning.
Finally, and of most concern, significant water pollution has been measured in the Elk and Fording rivers downstream of extant coal mining operations, with evidence of negative impacts on aquatic ecology and sources of drinking water. There is no indication that there is the long-term will or the technology for the coal operators to cost-effectively remove contaminants from the water before they enter our river systems. Some of these contaminants will threaten species-at-risk and may cause enduring, bio-accumulative impacts on downstream use, including natural ecosystems, municipal drinking water, irrigation and intensive livestock operations. In other words, there is no point trading temporary gains for permanent losses for a livable future in the region.
In summary, the unilateral decision to promote coal mining on the Eastern Slopes and in our headwaters risks the long-term welfare of our economy, our wildlife, our ecosystem and our own health.
The proposal to greatly expand coal mining in our headwaters also requires much greater public consultation; it requires a comprehensive water allocation plan; and it requires greater consideration of long-term cumulative effects of water contamination to downstream users. It should also be emphasized that the decision to sell more coal mining leases prior to the recommendations from the Joint Review Panel is unutterably inappropriate.
Coal, Calcite and Cutthroats
Published in, Lethbridge Herald
26 November 2020
Calcite build-up on streambeds is an environmental hazard of open-pit mountaintop coal mining proposed in the headwaters of the Oldman River. As with selenium pollution, described in a previous article, water flowing through waste rock accumulated during the coal mining process dissolves calcium carbonate and carries it downstream. Unlike selenium, calcium carbonate is not considered a toxic pollutant in water. However, when calcium carbonate reaches a high enough concentration, it solidifies into calcite. The process is similar to the buildup that forms in tea kettles and humidifiers. Calcite coats the stream bottom and, in effect, turns it into concrete. In some cases streambed sands and gravels can only be broken free with hammer blows.
Where calcite accumulates, the stream bottom becomes uninhabitable to invertebrates that form the base of the aquatic food chain. Aquatic plants are smothered. Trout that use an undulating movement to flush sediment and excavate hollows in loose gravels for laying eggs, referred to as redds, can no longer spawn. This is especially devasting to native cutthroat and bull trout, both “threatened” species, federally and provincially.
In reaches where a stream bottom becomes cemented, bank erosion increases causing more sediment to be released and the stream to over-widen. This impact on streams has previously been observed in Eastern Slopes watersheds experiencing a high degree of surface disturbance from logging and other industrial development, including Racehorse Creek and Dutch Creek. Adverse effects on reproduction of native trout have been noted.
Calcite formation is occurring downstream of coal mines operated by Teck Resources Limited in southeastern BC in the Elk River valley. Monitoring has detected increase in calcite over time with 30% of the river and stream channels surveyed in 2018 impacted by calcite at levels higher than background. Recent studies to assess effects on Westslope Cutthroat Trout, a Species at Risk, found density of redds decreased as calcite concentration increased in stream reaches.
Teck, under its permit to operate, is required by Environment and Climate change Canada to reduce calcite levels in mine-affected streams in the Elk Valley. This direction is issued under the federal Fisheries Act. Since October, 2017 the company is experimenting with adding antiscalant (a chemical that inhibits formation and precipitation of crystallized mineral salts) to a stream to inhibit formation of calcite. A geo-synthetic cover over waste rock is also being tried to prevent water leaching of calcium carbonate. Cost of these mitigation measures is estimated to be several hundred million dollars.
The proposed Grassy Mountain Mine north of Blairmore straddles the valleys of two streams that are habitat for Westslope Cutthroat Trout – Blairmore Creek and Gold Creek, tributaries of the Crowsnest River. This native species once inhabited most streams in southwestern Alberta from the alpine to the prairies, but now occupies only a small fraction of its original distribution. A strategy for recovery of its habitat has been developed and is in the process of being implemented. If the mine is allowed to proceed, recovery efforts will be undercut and calcite build-up in spawning habitat would become one more risk pushing this threatened species to the brink of extinction.
Selenium's Impact on the Environment
Published in, Lethbridge Herald
23 October 2020
As residents living along the Oldman River anticipate the impacts of open-pit coal mining in our headwaters, we should know more about the potential changes in water quality and their effects on river health and, therefore, our health.
Open-pit coal mining involves the removal of rock that sits above the coal seams that the mining company targets for extraction. This rock, or overburden, is typically dumped into the river valleys near the mine where it is exposed to weathering. It is the weathering process that releases pollutants like cadmium, nitrate, sulphate, iron, uranium and selenium into the environment over time – in the form of particulates in the air but, more significantly, into river systems.
Like some other elements, selenium is biphasic which means that it is necessary for life in small concentrations but becomes toxic to aquatic species in concentrations as low as 1.5 mg/l. Selenium ions are soluble in water, so they don’t settle in containment ponds. When released to the environment, selenium (as selenite and selenides) bioaccumulates in the aquatic system. That is, the selenium increases in concentration as i