This opinion letter is submitted on behalf of What Matters in Our Valley, which is a newly formed group of residents of Telkwa and other areas in the Bulkley Valley.
We are concerned about the recently announced plans by Allegiance Coal to submit an application to begin open pit coal mining operations in an area in close proximity to Telkwa and to the Telkwa and Bulkley Rivers. The initial open pit operation (called the Tenas Pit by Allegiance) will be about the size of Tyhee Lake.
According to press reports and other information we have gathered, Allegiance is intending to file its application sometime in late 2018. In order to speed the process by avoiding a full environmental review under the Environmental Assessment Act, Allegiance has decided to file this as a Small Mine application under the Mines Act with the objective of beginning operations in 2019.
Allegiance states in its “Market Update” of Jan. 18, 2017 that its initial plans are to limit mining to 240,000 tons per year (tpa) which would place it just below the 250,000 tpa threshold that would trigger a full assessment under the Environmental Assessment Act. Yet, in the same document, Allegiance states that it plans to increase production to about 1.5 million tons per year. Also, Allegiance has cited the total reserve in the Telkwa Coal deposit as amounting to 165,562,000 metric tons. Allegiance also states that its intent is to open at least two more pits during the life of its operation. Clearly, the proponent’s aims are to mine far more than 240,00 tpa.
Not surprisingly, the proposal raises substantial concerns among area residents. There is a long and controversial history of similar plans to mine coal in this area dating back to 1982 when the first modern proposal to re-open the Telkwa coal mining area was raised.
The location of the proposed mining project is a highly sensitive one lying as it does near the confluence of the Telkwa and Bulkley Rivers with their large runs of salmon and steelhead. The project concerns so-called metallurgical coal which requires cleaning at the mine location. Such cleaning produces huge amounts of waste water which will include acid rock drainage and other materials toxic to fish.
The proposal also raises serious traffic, noise and air pollution concerns for residents of the village of Telkwa. Coal will have to be trucked from the open pit mines that are contemplated by the proposal to a rail siding that lies on the other side of the main Telkwa residential area. The current planned route is on the road that passes directly through the centre of Telkwa. The plans for the initial operation call for two trucks per hour to pass through the village on the way to a railroad loading site off Lawson Road. Should the mine ramp up to the full 1.5 million tpa capacity contemplated by Allegiance, this would presumably expand to over 12 trucks per hour.
Moreover, the project lies wholly or mostly within the recently established Telkwa Mountains Caribou Wildlife Habitat Area. This area was recently designated in order to protect the threatened Telkwa Mountains caribou herd which is expressly listed under a schedule of the Species at Risk Act, which requires Provincial efforts to preserve habitat to ensure that the herd can be saved from extinction.
The proposal lies within the traditional territory of the Wet’suwet’en people. While the Wet’suwet’en are no doubt conducting their own process to determine whether this is a project that they can accept, their deliberations would surely be aided by a full environmental assessment conducted by the Province.
Under these circumstances, we are concerned that the proponents intend to avoid a comprehensive environmental assessment before starting operations through artificially minimizing the full scope of their project. The Environmental Assessment Act , Part 2, Sec. 6(1) allows the Minister of the Environment to require a full assessment even when the proposed mining project falls below the 250,000tpa threshold. Given the history and sensitivity of this area and the environmental risks associated with this project, we believe that the proposal meets all of the criteria necessary to require a full assessment even if the proponent’s 240,000 tpa estimate were to be taken at face value. Any other result will jeopardize the rivers, the fish the water and the air quality that the people of this region hold so dear.
Jay Gilden
For What Matters in Our Valley