Re: Release of AIR/EIS Guidelines for the Raven Underground Coal Mine project.
The Comox Valley Conservation Strategy (CVCS) is a community partnership made up of 20 local environmental and residents’ groups who have come together to support a Valley-wide conservation plan.
This strong collective voice for the local environment is deeply concerned about the inadequate Assessment Information requirements and Environmental Impact Statement (AIR/EIS) Guidelines recently approved for the proposed Raven project.
During the drafting of the AIR/EIS, we participated in the public consultation process as part of the environmental assessment review undertaken by Canadian Environmental Assessment Agency and the BC Environmental Assessment Office (CEAA/BCEAO).
In our submission to that process we outlined a number of potential environmental impacts the mine posed on freshwater, marine and land-based ecosystems and the flow and quality of surface and groundwater. Other concerns identified in our submission included —impacts to species at risk, air quality and risks to the sustainable shellfish industry in Baynes Sound.
In June 2012 the AIR/EIS Guidelines document was released for the mine project. Unfortunately, the guidelines are inadequate and fail to address many of the concerns raised through the public consultation process. The guidelines will not ensure that the project’s environmental impacts will be mitigated or that they will even be adequately monitored.
The guideline requirement to assess and monitor effects on hydrology from mining activities is restricted to testing five wells, representing only 10 per cent of the area proposed for mining. The hydrological study of potential impacts is confined to only two watersheds within the project area, excluding other watersheds such as the Tsable River and Wilfred Creek.
The baseline measurements that will be used to monitor the volume and quality of surface and subsurface water are based on incomplete and inaccurate information. The changes to aquifer volumes and quality of water over most of the area where mining operations will occur will not be measured.
The environmental assessment requirements to mitigate and monitor hydrological impacts were reviewed by an independent third-party engineering firm, GW Solutions.
In a letter outlining their findings, they say, “As a consequence, the assessment of the effects the proposed project will have on the streams will be poor. Similarly, the risk identification, the future monitoring, and the proposed remediation plan will be inadequate. This will jeopardize the sustainability of these streams and their associated ecosystems.”
There has been no requirement established to consider the impact of the Bear Coal deposit even though Compliance Coal has stated their intention to mine this site if the Raven project gets the go-ahead. The Bear Coal deposit is located in the Comox Lake Watershed, the primary drinking water source for Comox Valley residents.
The CVCS has stated from the outset that we do not support a coal mine in the Comox Valley. Unfortunately, the AIR/EIS guidelines for the proposed Raven Underground Coal Mine project not only lack any consideration of global impacts, but also fail to ensure that a coal mine would be operated without long term negative consequences to the health of our local watersheds, marine and land-based ecosystems, and our sustainable shellfish industry employing 600 local residents.
Editor’s note: David Stapley is the project manager for the Comox Valley Conservation Strategy.