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Comments on Proposed Terms of Reference for the Mount Klappan Coal project assessment

webmaster : Apr 20.2007

To: Anne Curry, Project Assessment Director, BC Environmental Assessment Office
Subject: Comments on Proposed Terms of Reference for the Mount Klappan Coal project assessment

January 8, 2007
 
Re: Terms of Reference for the Environmental Assessment of the Mount Klappan Coal Project

 

Dear Ms. Curry,

Thank you for the opportunity to provide comments on the proposed Fortune Minerals’ Terms of Reference for the Environmental Assessment of the Mount Klappan Coal Project. I am writing this on behalf of the Transboundary Watershed Alliance. We are an Alliance of over 20 environmental and conservation organizations from Southeast Alaska, Yukon and British Columbia that work to ensure destructive development does not compromise overall ecosystem health or undermine the long term sustainability of communities in the Transboundary region. The Transboundary region consists of the watersheds from the Tatshenshini-Alsek in the north to the Unuk in the south that flow from British Columbia into Southeast Alaska. The Stikine is the largest watershed in the Transboundary region and its astonishing cultural, wilderness and biodiversity values demand the highest standards of management and the meticulous application of precautionary principles. I have visited the area that would potentially be impacted by the Mount Klappan project a number of times and have been witness to the increasing development pressures in that entire region.

Before I commence with my project-related comments, I want to mention a concern I have about the timing of the public comment period. EAO ought to take the matter of public consultation more seriously than is demonstrated by the decision to schedule the Klappan consultation process to coincide with the winter holiday season. It is self-evident that the communities and land-users potentially impacted by this very large project are going to be largely preoccupied with holiday preparations like the rest of Canada at this time. It is therefore a disservice to those same people to require them to do this kind of detailed analysis through this period. A delay in the consultation process into the new year would have been appropriate and would have signaled a more sincere interest in hearing and addressing people’s concerns.

The following are my key comments and concerns related to the Terms of Reference:
 
– The Project Scoping is too limited:
The Project will have impacts typical of any long-haul mining operation in an area of dense wildlife populations and should be assessed as such. In fact, the access road using the existing rail grade runs through an area that is immediately outside the Park complex that includes the Spatsizi Plateau Wilderness and Spatsizi Headwaters Parks so it will be particularly prone to wildlfe impacts and should be scoped as such. The long term viability of wildlife populations in the parks needs to be included in the assessment, examining the Ealue Lake road, the existing rail grade, and any new access route development associated with the project. The rail grade runs through areas identified in the Cassiar-Iskut Stikine LRMP process as being high grade Grizzly bear, sheep, moose and caribou habitat.
 
The scope of the project must include the proposed coal-fired power plant. Fortune Minerals has referred to such a plant as a power source, and it would have obvious air quailty and other environmental impacts as well as potentially creating impacts to scenic beauty in an area identified in the LRMP as a Recommended Scenic Area. The plant and any and all other support infrastructure  should be assessed carefully.
 
– Cumulative Effects Assessment is incomplete
There are some glaring omissions in the cumulative environmental effects section. The proponent rightly identifies “other identified developments such as the Eskay Creek mine, Forrest Kerr hydro, Red Chris mine, proposed Galore Creek mine project, possible extension of the BC Hydro grid from Meziaden, as well as existing tourism operations in the region” for consideration in the CEE assessment. All of those projects must be included, but the CEE cannot be limited to projects currently in the EA process. Other obvious projects that must be considered but were not listed are the massive impacts that would result from Shell developing the coal bed methane reserves in the Klappan, or  West Hawk Development Corporation’s Ground Hog coal project to the south. and any upgrades or extensions to the rail grade.
           
The proposed coal-fired power plant mentioned in the section above should also clearly be considered with respect to CEEs, as well as any transmission lines to link it to the grid.

Cumulative effects assessment should also go beyond environmental impacts to look at cumulative socio-economic and cultural impacts.

– Consultation
It is premature to support or reject a process of consultation until a clear framework for consultation has been negotiated between the proponent and the Iskut First Nation and others who stand to be most impacted should this project move forward. Environmental Assessment legislation in British Columbia includes the requirement that the review reflect government policy, so the New Relationship commitments by British Columbia should apply with respect to consultation.
 
– Existing Use of the Lands in Question
I saw the Chief of the Iskut Nation publicly declare the importance of the Klappan region to her people for a variety of land-based pursuits and practices. Those activities and the potential for them to be impacted by this development must be fully contemplated in the assessment. The same must apply to any other existing users of the land.
 
– Climate Change and Canada’s Agreement to the Kyoto Protocol
In the assessment of the Tulsequah Chief mine, Canadian assessors noted their concern that long haul distances needed to be examined in the context of Canada’s signing of the Kyoto Protocol. Similar haul distances are contemplated for the Mount Klappan project and those concerns are exacerbated by the scale of the project, the unique climate change impacts associated with the end use of coal, as well as the prospect of a coal fired power plant at the site. All of these factors should be considered in assessing this project as well as the potential for climate change impacts to exacerbate project and cumulative impacts.
 
– Wildlife and Habitat
Clear identification of the full extent of the use of impacted areas by wildlife must be a precursor to the assessment and those determinations must be over time and through the seasons. As I mentioned above, the access routes to the site and the mine site itself are noted as habitat for a variety of wildlife species. Access along new or existing routes must be carefully managed to avoid the impacts that have occurred elsewhere in this region due to road development or upgrading.
 
– Access
The applicant must better explain why a proposed second road route to the mine is necessary given the profound wildlife impacts associated with access development in wildlife habitat and the specific experiences with road impacts in this region (Golden Bear, Eskay Creek).

Sincerely,

David MacKinnon