This presentation will cover (1) properties and processes of sulphidic rock and how they affect drainage; (2) sulphide geologic materials; (3) challenges and requirements; and (4) tools and procedures.
Food production, housing, energy production, health care and transportation all depend on products from mining sulphidic rock. People’s need for the products of sulphide mining mean that the question is not whether there will be sulphidic mining but whether we will manage sulphidic mining responsibly. Ensuring well informed, environmentally sound mining and management of closed mines is important both for jurisdictions with many mines and society in general.
Bill is a soil scientist whose interest in mine reclamation resulted in a career primarily focused on the prediction and mitigation of metal leaching and acidic drainage. His experience includes working for BC Ministry of Mines, industry, consulting, and now Natural Resources Canada. Bill moved to Smithers in the 90s to regulate the many mine closures and mine openings in the region.
Writer has a message for Allegiance Coal.
Jul. 6, 2018
To Allegiance Coal Ltd.:
Please leave the coal in the ground. Remember, clean waterways are the lifeline to our future. Please do not be so arrogant to assume you can ruin ours here in the Bulkley Valley.
Writer is headed to Telkwa Coal open house Nov. 28 to ask about water use, Nov. 28, 2018
This is an excerpt from the Tenas Coal Project Description that was sent to the Environmental Assessment Office for preliminary review:
Water Supply and Management:
Water for site services, including process water make-up and wash-down and utility requirements, will come from groundwater wells or ponds located adjacent to the plant and pit areas. Preliminary hydrogeological and hydrology studies indicate that water sources within the Project area are adequate to meet the Project’s needs. More detailed information on average and maximum daily water demand for the Project will be developed during the detailed design stage; but is estimated at 15,000 litres per hour. Potable water will be sourced from groundwater and surface run off where possible. If sufficient supplies are not present, it will be sourced from Goathorn Creek. If required, this will be supplemented from potable water providers in the RDBN.
We are at record low water levels in our rivers. Climate change is a huge problem. Is no one concerned about a proposed coal mine using 15,000 litres/HOUR for the next 25 years or so? This is just one of the many questions I intend to ask at the Open House on Nov. 28th.
Anika Gattiker, Telkwa
The company says the project could be a net positive on the herd through local restoration efforts
A retired ecosystems biologist says he has concerns about how a proposed Telkwa coal mine could affect local caribou numbers.
Len Vanderstar was part of a Telkwa caribou herd recovery project in the 1990s which the saw a dwindling population (as few as six caribou with no calves observed in 1997) supplemented with 32 animals from the Sustut-Chase herd.
Despite what Vanderstar characterized as a number of people who were very critical toward the plan, it was a success.
The program increased the herd from six in 1997 to 114 recorded in July 2006 and is one of only two successful caribou recovery programs in the country (the other was in Gaspé, Quebec).
At a Jan. 15 talk at The Ark in Telkwa, Vanderstar brought up a number of concerns he has about how the Tenas coal pit, a proposed coal mine located seven kilometres southwest of Telkwa, could negatively impact the herd.
The Tenas pit is one of three coal deposits owned by Telkwa Coal Limited, which is 90 per cent owned by Allegiance Coal and 10 per cent by Itochu Corporation of Japan. The other two (referred to as the Telkwa North and Goathorn deposits) are also located at points southwest of the village.
Currently, the Tenas Project is Allegiance’s flagship project in the area, with a potential mine life of at least 25 years.
Central to Vanderstar’s concerns was the close proximity of the proposed development to a well-known part of the Telkwa mountains known colloquially as the Camel Humps.
He said the location is essential to caribou reproduction.
“These caribou go out and isolate themselves … have their calves and within two weeks all the mommies get together and they all congregate and they usually congregate in the camel humps.”
Vanderstar also said the animal is relatively unique in its preference for selecting habitat for seclusion versus the resources it contains.
“Moose and deer preferentially select habitat for forage supply, that’s why you find them in your backyard,” he explained.
“Caribou preferentially select habitat for avoidance, you could have the highest-quality habitat but if there’s going to be predators there or if there’s human activity there … they will move to substandard habitat because their number one choice is to get away from disturbance.
With that in mind, Vanderstar said there is also the issue of noise from blasting.
He pointed out the proposed Tenas pit is only seven kilometres linear distance from the edge of the camel humps.
“There is no sound barrier,” he said. “When you’ve got dynamite going off in a coal pit what do you think of the sensory disturbance to caribou?”
Vanderstar acknowledged he didn’t have a definite answer, but said the possibility for a negative impact on the local herd was a big concern for him.
He said he would like to see the company do sound modelling for how dynamite reverberates off the geography between the Tenas pit and the camel humps area.
“I would like to see Alliance Coal do it … have them do the blast, and lets see how it funnels up these valleys.”
He noted it would be a relatively easy test to do.
“I’m not aware that they’ve done it and it’s a concern that I’m raising.”
Vanderstar said it was important to note he wasn’t saying the proposed development would spell doom for the local herd, rather that he wanted to see concrete evidence the company had done their homework with regard to caribou populations before they proceed.
“I would like to have the comfort level that there’s some really good work done on this before we start [saying] that yeah this is permissible activity here.”
In response to these concerns, Angela Waterman, Telkwa Coal director of environment and government relations called the provincial environmental assessment process quite robust.
Currently the project is in what is known as the pre-application process, which means the company is having conversations with the relevant ministries — both federal and provincial — on topics ranging from air quality to water to things such as caribou habitat.
Waterman said right now the company is working with government to define the assessment methodology.
This includes working with the relevant decision makers to determine things like study areas for the project’s required environmental assessments.
Currently the provincial Environmental Assessment Office review of the Tenas project is on hold.
The decision was made in September 2019 in response to a request from the Wet’suwet’en — specifically the Cas Yikh house membership, Dini’ze and Ts’ahe’ze.
“Last summer the Wet’suwet’en approached us and said that they were dealing with other matters and asked us to pause the process until April and so we’ve done that,” said Waterman.
The Wet’suwet’en have previously indicated they will need until April 30 before they are able to proceed.
As for things like the impact of blasting on the local herd, that’s something Waterman said will be under the purview of the review.
“The environmental assessment will look at a bunch of things [such as] habitat and the potential for indirect and direct effects,” said Waterman.
She said indirect effects could include things like the potential for sensory disturbance from sound and that modelling of sounds such as blasting and mine machinery are part of the assessment being done. The results of that modelling will be reviewed in the environmental assessment.
Waterman also noted the Tenas Project’s area is out of the Telkwa caribou herd’s core habitat, instead within what is known as connective habitat or “the matrix.”
But Waterman also said the company took the issue of the herd’s well-being seriously.
“Telkwa Coal understands that the Telkwa caribou herd is of environmental and socio-cultural value,” she said.
With that in mind, she said many people working with the company have worked on caribou recovery in the past, such as Sean Sharpe, who also worked on the Telkwa caribou recovery project and is now on the Tenas technical team.
“We have very well-respected caribou experts on our project and we will be working on mitigation measures with the team and the federal and provincial government and key people on the working group such as the Wet’suwet’en,” she said.
Waterman said the company shares the community’s goal of wanting to ensure the environment is protected.
“Folks need to understand where the project is within the regulatory process timeline,” she said. “Some of the questions being asked and comments coming in are premature.
“Everybody is going to get a chance to provide input as to what is the best type of mitigation measures for this herd.”
Waterman ended on a positive note, raising the possibility for the development to actually benefit the herd.
“Aside from having all the right people at the table the project provides an opportunity to have a net positive effect on caribou in terms of what we could do in mitigation which would include restoration and offsetting,” she said.
“Areas that we don’t disturb or [which have] been disturbed by others, there are opportunities to rehabilitate some of those areas and at the end of the day there’s a potential for a net positive effect on caribou.”
Waterman said she thought the project would benefit greatly from what she described as a wealth of expertise in the area on the Telkwa caribou herd, adding the collective knowledge will likely directly or indirectly have a part in the review of the Tenas project as it relates to caribou.
“With so many experts, I would say the EA review is in good hands.”
The Jan. 15 talk was put on by What Matters in Our Valley, which was founded in 2017 by a group of Telkwa and other Bulkley Valley residents who “share a deep commitment to the conservation of our rivers, water, fish, wildlife, air and the quality of life in our exceptional area.”
The group’s current stated goals are to inform the public about the implications of the proposed Telkwa coal mine and to protect the interests of the local environment and economy.
The well written article by Trevor Hewitt regarding concerns about potential impacts that the proposed Telkwa Coal mine may have on Telkwa Caribou was informative. I would like to raise some additional comments for the readership.
A consulting biologist for Allegiance (Telkwa Coal) stated that he was not aware of any acoustic disturbance studies yet initiated. It is reported that Angela Waterman (Telkwa Coal Environment & Government Relations Director) stated that this will be under the purview of the pre-application process of environmental assessment. The point being is that Allegiance has yet to conduct such a study despite a couple of public open houses that presented studies to date including conceptual project design, and public comment solicitation.
It is reported that Angela rasied the possibility that the coal mine development could actually benefit the herd. Given the limited
habitat currently in place, any further habitat reduction will not be beneficial to the Telkwa Caribou, period. If we start treating the caribou like captive zoo animals via putting dollars into maternal penning, predator reduction and winter supplementary feeding, then yes the Telkwa Caribou population could benefit, but is that the way we want to manage our ecologies? This is what is partially implied by Angela’s comments. Regarding habitat restoration, yes this would be beneficial and an infusion of cash from industrial developments such as a coal mine or LNG energy corridor in the Telkwa Caribou Recovery Area could make this a reality, but over what remaining already fragmented habitat?
Len Vanderstar, R.P.Bio
9 things you need to know about the proposed open-pit coal mine near Smithers, B.C.
Australian company Telkwa Coal wants to build the mine in a caribou recovery area and just a few kilometres from an important salmon watershed in Wet’suwet’en territory
Matt Simmons, Local Journalism Initiative reporter
Telkwa, B.C., is a small town at the confluence of the Telkwa and Bulkley rivers, 15 kilometres south of Smithers. Surrounded by mountains, the area is known for backcountry recreation, hunting and fishing, and abundant wildlife. In the fall, steelhead fishing enthusiasts from around the world flood the community. In the winter, skiers, snowshoers and snowmobilers head into the mountains.
Agriculture is a key part of the local economy. Farmers raise cattle, pigs and other livestock as well as myriad crops. The rivers are rich in salmon and provide an important source of food for the Wet’suwet’en, whose unceded territory the town dwells on.
An open-pit metallurgical coal mine is proposed for a site just seven kilometres away from the town, on a natural bench between Goathorn and Tenas creeks, both tributaries of the Telkwa. The mine would be in a caribou recovery area and just a few kilometres from an important salmon watershed. As the Tenas project proceeds through the provincial environmental assessment process, locals are raising concerns about potential impacts on water, wildlife and lifestyle.
1) What’s the history of coal in Telkwa?
Since the early 20th century, coal mining has played a prominent role in the community’s history. One of the town’s main roads is even called Telkwa Coalmine Road. For more than 50 years, the fossil fuel was used locally and transported by rail. By the early 1970s, operations dwindled, but exploration never stopped.
Telkwa Coal — 90 per cent owned by Australian company Allegiance Coal and 10 per cent by Itochu Corporation of Japan — is the latest of several companies to propose a mine near Telkwa.
In 2014, Telkwa Coal acquired the rights to the site after multiple companies failed to develop a mine on the location. In 2017, talks began with the Office of the Wet’suwet’en and the provincial government.
2) How big is Telkwa Coal’s proposed mine?
The proposed Tenas coal mine is estimated to extend just over 1,000 hectares by the end of its 25-year lifespan. That includes a haul road, sediment ponds and a containment pond for potentially acid-generating rock, which is rock that can form acid when oxidized. That acid can then leach metals that can be harmful to aquatic life.
Tenas would be a much smaller operation than Teck Resources’ Elk Valley mine, which spans approximately 5,000 hectares and produces 10 megatonnes of steel-making coal per year. The Tenas coal mine would produce approximately 775,000 to 825,000 tonnes of steel-making coal annually.
The proposed Tenas project is now going through the B.C. environmental assessment process. A draft application information requirements document, which sets out the parameters of what the company needs to look at in terms of potential environmental impacts, has been submitted, and the public can comment on the project until July 23.
“We welcome feedback from the public and this feedback guides our decision-making,” said Angela Waterman, Telkwa Coal’s director of environment and government relations. “We believe that we can operate the mine safely and responsibly and deliver long-term benefits to the community.”
3) With the Telkwa Coal mine proposed so close to the community, what are residents concerned about?
Nancy Cody — a resident of Telkwa and member of What Matters in Our Valley, a community group working to keep locals apprised of the proposed project — has been monitoring mine development plans since the 1980s. She isn’t convinced a coal mine in her backyard is safe.
“To me, the biggest risks are to the water, the wildlife and the fish,” said Cody, who’s lived off-grid in Telkwa for 40 years.
She told The Narwhal she attended a public consultation event for an earlier project proposed on the site. “Our house was smack dab in the middle of the load-out area.” Since then, she’s kept a close watch on any plans to develop the site.
Telkwa Coal touts the close proximity to town as beneficial. Existing infrastructure nearby lowers capital costs and means less impact on the landscape, the company said. Being situated so close to the CN rail line means the product can be shipped to market quickly via the existing coal terminal on Ridley Island in Prince Rupert. Plus, employees wouldn’t have to work in camps like so many mine workers in the region.
Locals are worried about the potential effects of the proposed Telkwa Coal mine on water in the region, including the Bulkley River, shown here just downriver from where it meets the Telkwa River. Photo: Dewey / flickr
“People look forward to having a mining job that will enable them to come home at night to sleep in their own bed,” Waterman said.
In a small rural town, opinions on development are often polarized. And Cody doesn’t want to be divisive.
“People are hungry for work, there’s no question,” she said. “But we need to create a more sustainable local economy. What can we do to create employment if coal is not the future? And coal is not the future.”
Waterman said the project will create 150 jobs during construction and employ 170 workers at peak operations.
The trade-offs for those jobs, Cody said, are significant risks to water and wildlife. She also points out that those jobs wouldn’t last forever as the mine would have a maximum 25-year lifespan, including construction and reclamation.
In addition to post-closure reclamation, the submerged potentially acid-generating rock would need to be monitored in perpetuity.
In B.C., mining companies give the government money in the form of bonds up front to cover the costs of reclamation and monitoring. But as The Narwhal reported earlier this year, the province only has $1.6 billion in bonds from mining companies to cover an estimated $2.8 billion in reclamation. If mining companies go bankrupt, taxpayers have to make up the difference.
Residents are also concerned about dust and noise from blasting, trucks and machinery.
Gabriele Schimke’s property borders Goathorn Creek and is just a few kilometres from the proposed site. She previously lived in Estevan, Sask., about five kilometres from Westmoreland’s Estevan coal mine.
“We had black dust in our apartment. It goes everywhere,” Schimke said.
Telkwa Coal said it will manage dust by spraying it with a combination of chemical binding agents and water at the mine site and during transportation. While technology to suppress dust both at the mine site and in transit has improved, respiratory diseases directly related to coal mining still affect workers today.
As for the noise, Schimke glanced at her horse, listed all the kids who live nearby and said: “We would hear the blasting from here.”
4) What environmental assessment is being done of Telkwa Coal’s mine?
The proposed coal mine is subject to the B.C. environmental assessment process. However, according to a statement provided by the Ministry of Environment and Climate Change Strategy, because the project had already started the process prior to the Environmental Assessment Act being updated last year, Telkwa Coal was given the choice to proceed under the new act or stick with the old one. It opted for the latter.
“It’s unfortunate that the Telkwa Coal process isn’t going through the new B.C. environmental assessment process,” said Nikki Skuce, director of Northern Confluence, a Smithers-based initiative that aims to improve land-use decisions in B.C.’s salmon watersheds. “It was updated for a reason. The old B.C. environmental assessment process approved almost every single project that ever went through.”
There are a couple of key differences between the old and new acts. For one, consulting with community advisory groups is mandatory under the new legislation. This means that a group like What Matters in Our Valley would have a seat at the table of working groups, rather than being on the sidelines. The group asked to be included in Telkwa Coal’s assessment, but the request was declined.
The new act also addresses professional reliance, Skuce explains.
“A massive issue with former environmental assessments was that the company would contract out different experts to do their environmental assessment studies, but they could also decide that they didn’t like the science and would just never release it and hire somebody else to produce more favourable results.”
The new act requires industry to contract the best available scientists. This government oversight means the science in an environmental assessment is independent and not geared toward finding results that support the company’s project.
Community members are also concerned the environmental assessment doesn’t require the company to report on studies assessing the potential effects of the mine on water — although it is doing such studies. This is because the water that might be affected by the project has not been designated a “valued component,” which, according to the Environmental Assessment Office guidelines, is a component of the environment deemed to have “scientific, ecological, economic, social, cultural, archaeological, historical or other importance.”
“It seems like that’s a glaring hole in the assessment,” said Jay Gilden, a member of What Matters in Our Valley. “If you don’t make it a valued component, then you don’t have to explain directly how you’re going to protect it.”
Gilden said although fish are included as a valued component, that has little bearing on the protection of the water.
“You can imperil the water, and as long as you can come up with some scheme for protecting the fish — put them in some side pond somewhere — it doesn’t matter what happens to the water. If you protect the watershed, then you protect the fish too.”
Gilden and others are attempting to address the omission through the public commenting process. “They shouldn’t be able to run the mine unless it is certain that it will not impact the water,” he said.
5) What are the Telkwa Coal mine’s potential effects on water?
For Gilden, Cody and Schimke, water is absolutely a valued component of the Telkwa Coal project. Each speaks to the importance of the local creeks and rivers, and the aquatic life they support.
“The water is pretty awesome here,” Schimke said. “You can just drink it right from the creek.”
If a catastrophic event like the Mount Polley disaster were to occur here, the downstream effects would be far-reaching. Severe acid rock contamination of the creeks and rivers would lower the pH levels to a point where no aquatic life could survive.
“This would impact the Skeena, the Wedzin Kwa, the Telkwa,” Cody said. “It impacts everyone.”
A large-scale event isn’t the only concern. With an increasingly unpredictable climate, many residents are concerned about what would happen in drought conditions. Telkwa Coal would need to divert water from the creeks to use in its operations, which would impact water flow downstream. Conversely, extreme weather conditions could create runoff from the tailings ponds.
And after the mine is eventually closed, the risk of acid rock drainage would last forever. It doesn’t take much to kill a river. The small Mount Washington mine on the Tsolum River, for instance, decimated the local fish population.
Skuce points to the Tulsequah Chief mine, an abandoned mixed-metals mine in northwest B.C. that has been leaching contaminated water for over 60 years into an important tributary of the salmon-producing Taku River.
“If a tailings pond or a mine is going to require water treatment in perpetuity, which means forever, and there is a risk to salmon, should we actually allow that to happen?” Skuce asked. “Because we have all these legacies that show we probably shouldn’t.”
6) What are the Telkwa Coal mine’s potential impacts on wildlife?
The proposed project overlaps with the Telkwa caribou herd recovery area, a 1,300-square-kilometre region designed to monitor and protect the endangered herd. At the last count in October, there were just 32 caribou.
Retired ecosystems biologist Len Vanderstar was involved in setting up the protected area and recovery plan in the 1990s. He’s concerned that constructing a coal mine so close to vital habitat could reverse the successes in protecting the herd.
“What more cumulative impact can a herd take that is listed as threatened and in imminent threat of extirpation?” he asks. “How many more times will the dice be rolled before we blink these creatures off the landscape?”
The caribou historically used the Tenas Creek area, where the mine will be located, though not in recent years. But Vanderstar is concerned about the mine’s proximity to important post-calving grounds, known locally as the Camel Humps.
Vanderstar points out that the document outlining the issues to be covered in the environmental assessment doesn’t mention the potential of blasting to displace caribou, especially in the Camel Humps. “The proponent and government know about this concern, so why is it not reflected?” he asks.
This isn’t the first time a mine has been proposed in critical caribou habitat. The proposed Sukunka mine in the Peace region would directly impact the Quintette caribou herd, which is listed as threatened under the Species at Risk Act
7) Why are we mining coal anyway?
Canada produces about 60 million tonnes of coal every year — half of which is thermal coal for power generation and half of which is metallurgical coal, which is used primarily in industrial steel production. About 70 per cent of the world’s steel is made with coal, according to the World Coal Association.
Before it can be used, metallurgical coal has to be coked — a heating process that carbonizes it. It is then burned in a blast furnace with other raw materials — primarily iron ore — and most of it ends up as carbon dioxide.
Globally, the use of coal — both thermal and metallurgical — produces about 40 per cent of the world’s fossil fuel greenhouse gas emissions. Burning coal also produces particulates and other gases like sulphur dioxide and nitrogen oxides, all of which can impact human health.
There are alternative ways to manufacture steel that produce lower emissions. Manufacturers use electric arc furnaces to melt recycled scrap metal and produce steel. While this process produces fewer emissions than using coal, the furnaces require huge amounts of electricity. Several companies are also developing hydrogen technologies to create zero-emissions steel production.
“In terms of steel production, we need to look at other options,” Cody said. “This much we know: steel-making with coal is bad for the climate.”
8) What about the Wet’suwet’en?
Mark Gray, chairman and managing director of Allegiance and Telkwa Coal, is Māori. He opened a recent virtual open house with a traditional Māori greeting, speaking first to the Wet’suwet’en. The Office of the Wet’suwet’en is engaging with the company and the B.C. Environmental Assessment Office through working groups and consultation.
When the Wet’suwet’en asked Telkwa Coal last winter to put the project on hold while they worked through more pressing issues with the Coastal GasLink pipeline project, the company agreed.
“We paused for nearly eight months, I think it was, before we restarted, so that they could focus on other matters,” Waterman said. “And what we can say is our relationship is of great importance. Our role is to present a plan, to answer questions and address concerns.”
This doesn’t mean the Wet’suwet’en support the project. It just means they’re engaging with the proponent and following the prescribed provincial process. David DeWit, natural resources manager with the Office of the Wet’suwet’en, is cautious.
“Status quo process has proved to be inadequate for the [Coastal GasLink] pipeline project,” he writes in an email. “In a time when the Wet’suwet’en are defining how Wet’suwet’en title is implemented and informs B.C. process, we need courageous leaders from all parties: Wet’suwet’en, B.C. and the company.”
9) What comes next?
After the public comment period closes on July 23, Telkwa Coal will review the comments and submit a public consultation report to the Environmental Assessment Office. The application information requirements document is then finalized and the proponent conducts all the required studies to prepare its official application for an environmental assessment certificate.
Waterman predicts the application will be ready late this year or early next year. “At that stage, once we submit it, then there will be one or two other public consultation periods.”
Cody is dubious the project will go through, pointing out that one of the previous companies that tried to develop a mine at the site was Minalta, in the 1990s. At the time, Minalta was Canada’s largest coal-producing company. Telkwa Coal, in comparison, is what is known as a junior mining company, which means the company has no sources of revenue and is staking its future on the mine getting the green light. But she still urges the public to be involved.
“We believe people need to be commenting and engaging. People can make a difference.”
Having a big sale, on-site celebrity, or other event? Be sure to announce it so everybody knows and gets excited about it.
Local environmental group wants mining company to treat water as a Valued Component
Feb. 18, 2021
Just to let everyone know the current status of the Telkwa Coal project, it continues to be under review in the BC Environmental Assessment Office.
The stage it is now at is called a draft Application Information Requirement (dAIR). This document went through a public comment period. What Matters in Our Valley (WMIOV), together with close to 200 others filed comments.
One area of major concern involves what are known as Valued Components and Intermediate Components.
Valued Components are those features of our Valley put at risk by the mine project that either must be protected, or if not protected then be the subject of some degree of mitigation for any negative consequences.
Intermediate Components are features that will impact Valued Components if affected by the project, but do not need to be protected in their own right.
Telkwa Coal has identified water (i.e. our rivers, streams, creeks, water sources and any other water bodies) as Intermediate Components, but not Valued Components. This means that, if the dAIR is approved, their project can be allowed to go through even if the mine will damage our waters.
Telkwa Coal does identify the following Valued Components: Fish and fish Habitat; Vegetation; Wildlife; Birds; Heritage Resources; Human Health.
However, when it comes to water, they just don’t think it is all that important standing on its own. So, as long as they can present a plan that, for example, doesn’t according to them put the fish or wildlife at risk, then it is alright to pollute the rivers and other waters.
We think this is fundamentally wrong. Given the current fragile state of our fish and other water-based resources, any additional negative impacts should not be allowed. We do not think that there is any mitigation that can make up for further damage to the aquatic environment.
But, beyond this, pure water and uncontaminated rivers are treasured features of our Valley. This has been true since the valley was first occupied by humans eons ago. It remains true today.
Telkwa Coal obviously just doesn’t get it. The Province should. The first step is for the Province to make water a Valued Component.
Please let our elected representatives at all levels know that we cherish our waters and they must receive the highest priority. You may also wish to contact the Environmental Assessment Office through Heather Noble (Heather.Noble@gov.bc.ca) and Matt Rodgers (Matthew.Rodgers@gov.bc.ca)
on behalf of WMIOV
Feb. 25, 2021
Re: “Does Telkwa Coal value the Bulkley Valley’s water?” letter to the editor, Interior News, Feb. 18, 2021.
Water is a vital resource and a critical part of the fabric that binds and supports our communities in the Bulkley Valley. At Telkwa Coal, we believe that healthy water quality and quantity are fundamental.
We also believe that every component selected for assessment in our environmental certification application is valuable and important – from water to wildlife and everything in between.
In response to feedback from the Office of the Wet’suwet’en (OW) and the public during the review of the Application Information Requirements (AIR), we looked at the use of the terms Valued Components (VC) and Intermediate Components (IC).
To clarify our commitment to the importance of each, and every component, we have put aside the technical differentiation and are using Valued Components only. Early in January, we communicated these intentions to both the OW as well as to the BC EAO.
While we initially followed the Province of BC guidance on selecting VCs and ICs based on the technical definitions as either a receptor (VC), or pathway to a receptor (IC), we heard separating components into these two categories falsely implied and was incorrectly interpreted as a differing level of importance.
This is not the case.
Every component whether identified as “Valued” or “Intermediate” is valuable and key to developing a robust assessment.
As part of the scientific review, each component will still be considered as either a pathway or receptor and will include consideration for how they connect to each other. For example, Water Quality is clearly linked to Fish and Fish Habitat and Human Health.
Further, whether a receptor or pathway, all components will be fully considered by Telkwa Coal and the regulators who review our application.
We hope this streamlined approach will provide a greater confidence in the effect assessment process and outcomes and look forward to sharing more about our project in the weeks and months ahead.
Director for Environment & Government Relations
Writer says sometimes public pressure does have some effect. Jul. 20th, 2018
Sometimes public pressure does have some effect.
As we pointed out in our last opinion letter in The Interior News (Feb. 15, 2018), Allegiance Coal, the Australian company that owns the Telkwa Coal open pit mine proposal, has repeatedly stated over the last 12 months that it plans to initiate operations at a level just below the B.C. Environmental Assessment Act’s threshold of 250,000 tonnes per year. At the same time, it has promoted its plan to investors and others as including a phased build-up that would reach as high as 1.75 million tonnes per year. We believed that the sub-250,000 tonne figure was an attempt to avoid the B.C. Environmental Assessment Act requirements. Allegiance actually seemed to state as much in its investor communications saying it wanted to take advantage of the more “defined” process available through the Mines Act.
Given the sensitivity of the location of the proposed mine near the confluence of the Bulkley and Telkwa Rivers and the Village of Telkwa, as well as the known threats posed by the potential for acid rock drainage from this mine, we asked that the provincial government exercise its discretion to require a full environmental assessment not withstanding Allegiance’s claims about the initial size of the mine.
As recently as the open house that occurred in Telkwa on May 23, Allegiance continued to insist that it planned to start operations at the below 250,000 tonne level and that it therefore did not need a full EA. During this time, many people wrote letters to the Ministry of the Environment asking that this effort to avoid its requirements be rejected.
Now, Allegiance has decided to give up this pretext due to what it terms “stakeholder” concerns. Allegiance is now openly acknowledging that it will start production at a much higher level, currently identified as 750,000 tonnes per year.
At the same time, despite its previously identified ultimate target of 1.5-1.75 million tonnes per year, Allegiance’s currently stated production objective will be below the 1,000,000 tonne threshold for a federally required Environmental Assessment (Allegiance is careful to point this out to the investor community). Thus, while the proclaimed increased size of the project will mean the proposal will be subject to provincial environmental assessment, it still won’t trigger a federal EA and we are concerned that federal interests like fisheries may not be fully examined
In any event, this appears to us to be a victory for those who want to make sure that if this mine is approved, there is a full analysis of and public consultation about its significant risks. These risks include those posed to our water through acid rock drainage and related leaching of heavy metals that are toxic to fish, to our air, to wildlife including the caribou recovery effort, and to Telkwa and the surrounding Bulkley Valley communities.
For What Matters in our Valley
Glenda Ferris has looked at past proposals and sees too much acidic risk with Telkwa Coal Project. Oct. 18th, 2017
The Telkwa Coal Project mine proposal being promoted by Allegiance Coal Limited is a major mine development. Within the legal framework of British Columbia, an Environmental Assessment process and Approval are required before any “operational permits” are issued to this company. There have been four decades of varying mine development proposals at this site, none of which proceeded to a BCEAO/BC Environmental Office Approval, let alone “permits.”
Acid Rock Drainage
Due to previous site inventory work — lab test results and field trials — we know that many rock types within the mine waste rock stream at this site contain sufficient sulphide mineralization to generate ARD (acid rock drainage). In simple terms, the minerals will oxidize into sulfide-state and when any water (rain, snowmelt, groundwater) flows to those locations, ARD will be the result. In addition, heavy metals such as manganese will be entrained within the acidic flows. Acidity levels will be sufficient to adversely affect the Telkwa and Bulkley Rivers if mitigation strategies are not effective.
Mine Site Inventory
Field trials on site were completed during the 1990s using silt stone, green sandstone and mudstone that are waste products at this mine site. The small deposits went acidic within 18 months. Another waste product identified has been the Coarse Rejects and the “wash stream waste,” both of which tested as acid generating. Several million tonnes of mine waste will be produced throughout the Telkwa Coal mine life; that mine waste will remain after the company is long gone.
Containment of Hazards for Rivers’ Safety
One of the primary principles with the B.C. ARD guidelines is that mine site ARD must be contained through ponds and/or collection systems. The principle of containment cannot be guaranteed at this mine site. At Telkwa Coal the coal seams are layered between aforementioned mudstones, sandstones, sand and gravels. This site condition means that flooded open pits, collection ponds and/or tailings
impoundment pond water levels may not be maintained through time, since sand and gravel lenses will provide drainage pathways to both the Bulkley and Telkwa Rivers.
If water covers are the “mitigation” for ARD-risks to prevent oxidation of sulfide minerals, and, due to site geology, water covers cannot be guaranteed, ARD will proceed due to wetdry cycle and groundwater discharges.
Major mine developments are mine waste storage facilities, forever. Waste rock, coal spoils and coal-wash rejects are the hazards. Included into this is the knowledge of past proposals have included eight open pits within the mine site footprint. Those pit walls will also become a hazard for ARD, since they may not retain a water cover over all sulphide-rock type layers year round.
Trade-off, jobs for long term damage?
I have assessed and reviewed three different mine proposals at this Telkwa Site. All of them represented several levels of high hazard conditions with no “trade-off” compensation that would balance the damage done nor the risks to our watersheds.
Writer says the risks of coal mine development near Telkwa are too high for area rivers.
Apr. 4th, 2018
As a regional environmental advocate, I participated in the Manalta Coal Ltd. British Columbia Environmental Assessment process, 1996-98. I was a member of the ARD/ML (Acid Rock Drainage and Metals Leaching) Working Group chaired by Craig Stewart, MoE/Protection Branch. During this past assessment of the proposed coal mine, there was detailed evaluation of the Tenas Pit and the two other additional adjacent coal deposits at the site. Several technical inventories are known due to our past work; these open pit coal deposits are not being accurately described by the Allegiance Coal Ltd. spokesperson.
First, the Tenas Pit has been measured at 3.6 km long; 1.3 km wide; 120 metres depth. This pit is not “a small operating footprint.” The final configuration of the exhausted open pit with exposed pit walls and pit waste rock dumps should be considered as a full operational mine life outcome.
This is a fact, not an opinion. This open pit has been proposed to be divided into three operational zones due to the extensive size and management requirements for stability of pit walls and lateral waste rock deposition. Past estimates for raw coal production are 20 million tonnes with 123 million cubic meters of waste rock and waste coal that will be placed in waste rock dumps immediately adjacent to the southern pit wall. *Ministry of Energy Mines Report 1997, page 2.
Backfilling of waste rock into the Tenas Pit cannot occur until one section of the pit is completely excavated; Waste rock backfill with partial flooding will result in a mined-out landscape of waste dumps and exposed pit walls, not a “lake.”
According to the Manalta Strip Ratio diagram, page 15 of the Allegiance Investor Report; October 2016, the strip ratio ranges between 0:1 all the way up to 20:1, that is, for every tonne of raw coal excavated, there will be 20 tonnes of waste rock. The so-called average for Strip Ratio has been estimated at 5.8 to 1. The geochemistry of the waste rock tonnage shows that there is little NP/neutralizing potential and substantial amounts of sulphide sulphur that will generate ARD/Acid Rock Drainage. The waste rock dumps created by the Tenas Open Pit operations alone would exceed 123 million tonnes at an NPR/Neutralization Potential Ratio of 1.74 — acid generating. Waste coal tonnage could increase this estimated mine waste volume.
Why do we care about mine waste? Because the waste rock and waste coal will be stored on site, forever. The coal will be sold and shipped, the mine waste stays in our valley.
The coal fields of Telkwa have been the location of extremely small-volume coal extraction with almost no waste rock produced and only small surface disturbance. While exposed coal seams and “shallow” coal has been extracted as thermal coal sales, we should all begin to understand that even at 240,000 tonnes of washed coal per year, the Mine Plan and the Waste Handling Plan will change the character and profoundly alter this landscape.
At average strip ratio and at 240,000 tonnes of washed coal annually, there will be at least 1,392,000 cubic metres of waste rock produced every year and placed into waste rock dumps along the southern edge of the Tenas Pit for 3.6 km and more. And there will also be mine waste produced by the Coal Processing Plant (coarse rejects and tailings fines) plus waste water from the Coal Washing Station.
The hazards of known, laboratory confirmed, acid rock drainage and the environmental risks of coal mine development all report to the watershed — to our rivers. No “community” or civil society sector has the right to place our watersheds in harm’s way.
Recipient of the Mining Association of BC “Award for B.C. Mining Sustainable Development”, 2001
Writer believes water and dust issues with a coalmine in Telkwa will ruin valley.
Apr. 25th, 2018
Years ago, we moved to Telkwa from Estevan, Sask., where we already experienced open pit coal mining.
Now Allegiance is planning an open pit coalmine approximately seven kilometres from our subdivision, hauling coal, two trucks every hour, four days a week, day and night along the existing Coalmine Road.
During a talk with Dan Farmer and Angela Waterman of Allegiance, we also voiced our concerns about our well water which comes from the Goathorn Creek. We were told not to worry, waste water would go via pipeline directly into the Telkwa River, but should we have problems with our water, we could apply for town water.
A pipeline to Telkwa? Town water? Not very reassuring answers.
They also spoke of 40-50 jobs that will be created by having a mine here. But what about the jobs that might be lost in the fishing and tourism industry because of noise and water pollution?
We do not want to watch Allegiance come here and destroy our scenic Bulkley Valley!
We love our home in beautiful Telkwa, where we can enjoy the outdoors and the wildlife.
A coal mine here, no thank-you!
Writer has some more questions she wants Telkwa Coal to answer.
Apr. 4th, 2018
Upon reading the March 26 article ‘Telkwa coal founder insists it will be a small scale mine,’ I feel compelled to respond. Managing director of Telkwa Coal Limited (and Allegiance Coal Ltd.) Mark Gray made some statements that have left me curious about a few important aspects of his proposed project.
First of all, Gray makes reference to the Telkwa Coal Project as being a “small scale mine” and he goes on to say that “there’s no sense in developing something we simply cannot raise the capital to build.” This sentiment is contradicted in Allegiance’s “Market Update” that is posted on their website. They state that remaining under a 250,000 tons per year (tpa) threshold would “not trigger a Federal Government review.” Allegiance goes on to use the term “ramping up” when it refers to coal production/extraction by Stage 2 of the project’s goals.
This is something I am puzzled about. Are they planning on starting small only to avoid a review under the British Columbia Environmental Assessment Act and/or a Federal Government review under the Canadian Environmental Assessment Act? Could this project expand gradually without a full environmental assessment being done?
Secondly, Gray stated that his company wishes to maintain a “small operating footprint.” It is important that we ask questions about land use prior to large projects so I did ask an Allegiance representative (months ago) about what needed to be done to set the stage for this Telkwa Coal project. Within the response I received, I remember hearing that thousands of hectares of land and trees would need to be disturbed. In my mind, that is a rather large footprint.
Finally, I have questions about water. This project is located near several creeks that are tied into the Telkwa River. The Telkwa River continues to flow into the Bulkley, then the Skeena. We are “upstream” and we are responsible to protect what is “downstream.” As a community, we are responsible for what happens to our salmon (and all others aquatic species) as well as our neighbours’ drinking water. Allegiance has stated that they will be drilling wells. The Telkwa Coal project will require enormous amounts of water for both a processing plant as well as a coal washing station. I would like Gray to review this process of water extraction as well as the consequences during an open house he will schedule.
Mark Gray’s company has put forward a two-page illustrated document that has been left at our Smithers Library for community to review. The document primarily outlines “how we use coal” and this is depicted using easy-to-follow clip art. What I was hoping to gather from Allegiance’s attempt to inform us are responses to the following questions: How will your company address ARD (Acid Rock Drainage) and the adverse affects to our watersheds? How will you deal with mine waste safely and effectively? How is your company assisting in the protection of the threatened Telkwa Mountains caribou herd in our forests and salmon in our rivers?
It is up to us to become better informed, to ask questions and to protect our valley’s watersheds, soil, wildlife and air. We have a company founder from Australia, employing directors from the Lower Mainland, to extract coal from our town of Telkwa, to sell their product to South Korea and Japan. My final question: is this a necessary and beneficial project for our community?
Writer says Telkwa Coal mine would present stark contrast to video productions on Telkwa website.
Dec. 6th, 2017
Maybe not “fake news” as we have come to know the term but if I hadn’t asked a lot of questions at the “limited” invitation open house that Allegiance Coal representatives held Nov. 8, I would have left there with quite a positive picture of a “small coal mine project” that would hardly be noticeable by the residents of our valley.
In reality, the proposed mine at the Tenas Pit across the Goat Horn Creek would present a stark contrast to the lovely video productions describing our community’s attributes and lifestyle that appear on the Telkwa Village website.
An open pit coal mine, a wash plant, a water treatment plant and a sediment pond to contain the acid rock drainage. Trucks hauling coal down Coalmine and Lawson Roads every half-hour through residential areas or along a new road that could be constructed over numerous creeks, through farm and crown land to the loading station by the CN tracks next to the Bulkley River. The coal would be loaded onto 150+ railcars and sprayed with “non-toxic” latex to keep the dust down.
There would be hardly any dust or noise (maybe a few daily explosions). And the big plus for Allegiance, since it would just be a “small” open pit mine with 240,000 tonnes/year, the whole process of applying for permits would only go through Ministry of Mines, which is a faster procedure. No Environmental Assessment would be required.
Any cause for concern? Not according to the Allegiance Coal delegates.