Senior Inspector of Mines, Permitting and Health and Safety
Ministry of Energy and Mines
PO Box 9395, Stn. Prov. Gov’t
Victoria, BC V8W 9M9
Dear Mr. Taje,
Re: File No. 100107874 – Application for a notice of work under section 10 of the Mines Act
Hillsborough Resources Limited (Woodhus Creek/Oyster River area)
Thank you for forwarding the above-noted referral for our comments. Hillsborough Resources Limited has submitted a notice of work that includes field mapping followed by a drilling program utilizing existing logging accesses. The sampling will be conducted within coal licenses 418448 and 418447 (Figure 1). The notice of work application includes four sample sites (WC-14-B to WC-14-E) within the Comox Valley Regional District’s (CVRD) jurisdiction (Block 28) and one sample site (WC-14-A) within the Strathcona Regional District’s jurisdiction (Figure 2). The five sample sites will cover a total area of 0.05 hectares. The proponents have noted that if favourable results are achieved, subsequent year programs will involve a comprehensive investigation of the potential coal resource through more strategic placed holes in higher density. Hillsborough Resources Limited noted that following each phase of work, full reclamation will be completed including cementing drill holes, backfilling any water supply/drill cutting sumps, re-contouring and scarifying any drill pads and access roads, and planting a representative tree species to return the area to its predevelopment composition. Given this, the CVRD offers the following concerns, comments and suggested future actions on this referral.
The CVRD board at its June 25, 2013 meeting outlined a concern to the chief gold commissioner that coal mine exploration could negatively impact existing industries, including aquaculture, within the Comox Valley. The board noted that “These existing industries are highly dependent on maintaining a healthy surface and subsurface environment. Specifically, past coal mines within the CVRD have left a legacy of environmental damage that continues to require significant provincial remediation investment. The CVRD requests that no coal license be issued.”
In general, the manner of extraction, extent of disturbance as well as impacts on related ecosystems, watersheds and aquifers requires further assessment prior to the CVRD being able to confirm consistency with the Comox Valley sustainability strategy, Comox Valley regional growth strategy (Bylaw No. 120) and rural Comox Valley official community plans. Therefore, the CVRD again requests that no coal license be issued (rescinded) and that no notice of work for exploratory drilling be issued.
The proposed notice of work area is located within the Oyster River watershed (Figure 3). The Black
Creek/Oyster Bay local water service area (LWSA) and the Watutco system obtain a portion of their water resources from this watershed. The Black Creek/Oyster Bay LWSA has 934 residential service connections and 39 commercial service connections while the Watutco system has approximately 172 residential service connections. The CVRD is very concerned that coal mining in this watershed could undermine the integrity of the drinking water supply.
Further, the CVRD’s sensitive habitat atlas identifies a number of confirmed fish bearing watercourses located directly on Block 28 and in the immediate vicinity (as well as unconfirmed fish bearing watercourses) (Figure 4). Thousands of volunteer hours and much public investment has been devoted to restoration of the Oyster River and its tributaries to ensure healthy ecosystems to support fish habitat. The CVRD recognizes that this application is outside of the authority of both the provincial Fish Protection Act and associated Riparian Areas Regulations. However, the CVRD board urges the Ministry of Energy and Mines (MoEM) to ensure that all activities undertaken by the proponent employ best practices and at a minimum comply with the Mines Act, specifically the Health, Safety and Reclamation Code for Mines in BC, which sets out requirements for environmental protection.
Finally, the CVRD urges the senior inspector of mines to consider the findings of exploratory drilling undertaken by Nuspar Resources in this vicinity in the late 1980’s wherein it was found that levels of acid run-off were too high to permit mine development.
If MoEM does consider issuing a notice of work permit to Hillsborough Resources Limited, then the CVRD board requests that the proponent addresses the following requirements:
aquifer protection measures including: an analysis on extraction volumes, aquifer depth, an aquifer permeability analysis and surveys to ensure aquifer depth is maintained;
groundwater management plans to protect the Oyster River watershed as well as adjacent property owners during the exploration phase;
measures to protect wildlife and human health during the exploration phase in accordance with the Health, Safety and Reclamation Code of BC;
flora and fauna baseline study of Block 28 prior to commencing exploration activities;
rain water management plans to ensure that any exploration does not result in drainage problems to the surrounding agricultural land reserve (ALR) lands and hydrology of the Oyster River watershed;
delineation of treed buffers adjacent to ALR lands in accordance with Ministry of Agriculture’s publication entitled “Guide to Edge Planning”; and
an assessment of the potential cumulative impacts (including, but not limited to: aquifers, marine, terrestrial and riparian ecosystems, air quality, metal leaching/acid rock drainage, mining extraction methods, public health and safety, climate change (i.e. greenhouse gas emissions) that are likely to result from this mining project in combination with other mining projects that have or will be carried out within the regional district. The CVRD board also encourages MoEM to host an information meeting to inform the public of the proposed exploration activities. Should you have any questions regarding the above, please contact Alana Mullaly, manager of planning services at 250-334-6051 or by email at firstname.lastname@example.org.