June 27, 2011
Union Bay, Vancouver Island, British Columbia
Rachel Shaw, Project Assessment Manager
Environmental Assessment Office
Government of British Columbia
Project Manager: Andrew Rollo
Canadian Environment Assessment Agency
Goverment of Canada
Raven Coal Mine Proposal Draft AIR
Not only have we found it difficult to know where to start with comments about deficiencies in the Raven Underground Coal Project’s Draft AIR, but we have also found it very difficult to decide whether it is even appropriate to participate in this process. But finally we have decided that it is best to put our concerns on record, and risk this effort being construed as legitimizing, or supporting in any manner the development of the proposed mine. Let there be no ambiguity: we are completely opposed to the development of this mine.
First, the joint government decision to not take this proposal through an independent environmental review has laid the ground for profound public mistrust, fear and anger. That Ministries of the Environment have, without independent detailed study, determined that there is not significant threat to a key shell-fish producing body of water and its related industry, the second most important bird area on the coast, the drinking and ground water of several communities, one of the country’s treasured old growth forests, and the Pacific Rim National Park only suggests a that there is a political “green light” for this project that has already dismissed any negative environment impact and that this whole process an expensive sham. We harbour a small and possibly naïve hope that this perception is wrong. We re-iterate here what you have heard over and over: the single biggest deficiency in the Draft AIR is that it relies on studies to be conducted by the company. This would be addressed by a Joint Federal / Provincial Independent Review Panel of Experts and full public hearings in all areas affected by this project. This process must include:
• a full and complete mapping and baseline testing of all underground aquifers and surface drainage systems onsite and off mapped by an independent group of experts. This must happen before any further site preparation goes ahead.
• a full accounting of the project’s carbon footprint, including the mine construction and operation, ground and sea transportation and coal combustion at destination points, and an independent expert assessment of the impact of the project’s carbon footprint on local and global climates
• an assessment of the impact of potential noise, light, water and air pollution (including dust and methane emissions) associated with the mine on all (not the small selection proposed by the proponent) species of affected flora and fauna, including the health of humans.
The Draft AIR’s sections on the economic and social impact of the proposal tell us only about sources the proponents will use to describe a limited number of “valued components”. It does not tell us how these will be assessed, or weighed, and we argue again that the proponent is not in a position to provide an independent assessment of the project’s impact. Independent social and economic impact studies must include all communities from from Qualicum to Campbell River and Port Alberni, Uclulet, Bamfield and Tofino. The studies must include:
• an explanation of how the project fits with the regional plans of all communities affected, including the Islands Trust. To the best of our knowledge, none of the local regional development plans, which are the result of extensive consultations and planning and are expressions of the aspirations and interests of the people who live here, have included coal development
• A detailed description of proposed mine and spin-off jobs, including skills and experience required, along with an equally detailed assessment of whether these skills can be found in local communities. If the skills are not available locally, the proposal must identify the likelihood of training local workers, and/or where trained workers are likely to come from and their numbers.
• An assessment of the health and safety impact of this mine environment for workers, including risk of black lung, other diseases and catastrophic events.
• A detailed estimate of the negative effect on non-mining jobs and industries, particularly the shell-fish industry, agriculture, tourism, eco-tourism and recreation
• A full accounting of the project’s public revenues and costs. The public costs would need to include highway repair and maintenance, mines and health and safety inspection, job training, increased hospital and emergency services use, and any increased school, social services and policing (see Fort McMurray). It also needs to include a realistic projection of any public costs associated with catastrophic events that could occur during mine construction, operation and decommissioning (Who Will Clean Up Our Mining Mess? Christopher Pollon, 23 May 20011, TheTyee.ca)
• Detailed drawings of above ground-mine operations and tailings piles, in the landscape, as they will be seen from key locations, particularly Denman Island and the Island Highway.
• Comprehensive social studies, including surveys, interviews, and focus groups, on the project’s impact on tourism, property values and the effects of a project that is opposed by a significant proportion of residents, including out-migration, mental health and community cohesion.
• A statement of the company’s commitment to workers’ health and safety, and corporate citizenship.
On a personal note, again for the record, if the Raven mine or any associated open pit mines proceed, it will be devastating for us. We moved to Union Bay a year ago, investing the sum total of our life’s work to come to a community that we understood valued and cherished one of the most beautiful environments on the planet. One of us has asthma, and we live close enough to the proposed site that coal dust may become a factor in our ability to stay here. We can barely think about the grief we would experience for this beautiful, still abundant environment, and the possible economic and social consequences for our lives if the mine becomes a reality.
Alice de Wolff