Photo © Jon Martin 2020.

There is significant interest in establishing coal mining operations throughout the eastern slopes of Alberta—the areas residing within the Oldman watershed are no exception. In this blog, we'll take a comparatively brief look at what coal mines mean for our watershed.

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What is coal used for?

There are two types of coal: thermal coal, which is used to produce electricity, and metallurgical coal, used to make steel. There are four coal companies proposing mines in the Oldman watershed, and all of them are for metallurgical coal. Any coal potentially extracted from our watershed would be transported by rail to the west coast, loaded on shipping tankers, and delivered to Asia. Steel is critical for infrastructure and construction projects, with demand growing in tandem with the needs of our cities.

*Mining areas in the province of Alberta.*

Mining in the Oldman Watershed

There is significant interest in establishing coal mining operations throughout the eastern slopes of Alberta (see map)—the areas residing within the Oldman watershed are no exception. Currently, there are at least four companies exploring potential mining operations in the region. All of the currently proposed coal mines are open-pit (a common surface mining technique that does not require tunnelling) and located in the Crowsnest Pass area. Coal exploration is also pending approval along the Livingstone Range, up to Highway 40.

Some of the land for the proposed mining projects is privately owned by the coal companies, while some areas are public land where mining companies have obtained, or applied for, permits which allow for the extraction of materials from public lands. A searchable database containing applications made to the Alberta Energy Regulator (AER) is available for members of the public to find out what could be happening in their area. Here is summary of the four proposed mines located in the Oldman watershed:

Riversdale/Benga’s Grassy Mountain Project - This proposed mine is furthest along in the approval process with the Environmental Impact Assessment (EIA) accepted as complete by both the federal and provincial governments. A Joint Review Panel has been established and hearings are being scheduled for October 2020.
OWC has reviewed the EIA for the proposed Grassy Mountain project. We have submitted a statement to the Impact Assessment Agency of Canada and Alberta Energy Regulator. Our statement to the Joint Review Panel is available here. We have asked to give a presentation to the Joint Review Panel at the hearings in October, 2020. In our statement, we highlighted what peer reviewed science indicates would be the likely impacts of this project and pointed out some areas where more research and/or information is needed.
Montem’s Tent Mountain Mine - Permit applications for restarting this old mine are under review.
Atrum’s Elan and Isolation Mines – Currently building roads and drilling exploratory holes to map coal and test quality; applying for approvals. An update was provided to the Municipality of Crowsnest Pass on July 14.
Cabin Ridge Coal Project Ltd. - Applied for a permit to drill deep exploratory holes to map coal and test quality.

2020 Coal Policy Change

The Government of Alberta (GoA) announced on May 15 they are rescinding the 1976 Coal Policy effective June 1, 2020 to encourage development. The 1976 Coal Policy organized land into four categories:

Category 1 - prohibited coal mining for environmental protection
Category 2 - surface mining not normally considered because lands are sensitive
Category 3 - mining may be allowed, with assurances for environmental protection, less sensitive lands compared to category 2
Category 4 - mining may be allowed, with assurances for environmental protection all other lands not covered by categories 1-3

*Coal Agreements and Coal Policy Land Classification in Alberta.*

The 1976 Coal Policy was one of the only prescriptive, sector-specific policies. Since it was introduced, the coal mine lobby argued that the policy was unfair and singled them out. At the time, Premier Peter Lougheed argued that it was necessary to manage environmental damage caused by mining operations in the province. Earlier this year, CBC News released a detailed history and captured the overall provincial story in an in-depth article, which includes video footage of Premier Lougheed discussing the policy.

With the 1976 policy being rescinded, new measures have been introduced by Alberta Environment and Parks. This includes implementing a ‘protective notation’ on Category 1 public lands (not private lands), which means they cannot be mined. These measures will be in place before new applications are accepted. It is unclear exactly what the parameters are for determining when an open-pit mine—versus subsurface mine—will be allowed. With the clarity provided by the 1976 removed, it is assumed that open-pit mines will now be allowed on all lands that do not have a protective notation (former Category 1).

The significant change is for Category 2 and 3 land; previously, open-pit mining was prohibited or discouraged on lands in these two categories. Now, however, it is presumably allowed. The Benga mine and Montem mine were on Category 4 lands, while the Atrum mine was on Category 2 land and so will benefit from this policy change. It is unclear which category of land the Cabin Ridge project is on.

Application Process for Mines

Before major construction or infrastructure work can begin on open-pit mines, mining companies must apply for exploration permits and, usually, a temporary water diversion license. These permits have a 30-day public comment period but are sometimes expedited, which means they can be approved prior to the 30-day comment period concluding.

The AER leads an internal and external review for all applications, including Environmental Impact Assessments. If the scope of a proposal is large enough, the federal government also reviews the proposal. Typically, a Joint Federal-Provincial Review Panel is established to hold hearings where directly-affected landowners, and experts and specialists with pertinent information are provided the opportunity to present their perspectives and any evidence that supports their position.

General overview of coal mine process: https://www.aer.ca/providing-information/by-topic/coal.html.
General overview of application process: https://www.aer.ca/regulating-development/project-application/application-process/coal-mining-authorizations.html.

In order to fully participate in the process, a person must prove that they are directly or adversely affected by the proposed project. Generally, this means a person must own property in close proximity to the mine. Environmental organizations, topical experts, and other affected groups are also typically allowed to participate if they are able to provide unique expertise and information about the project. First Nations are generally allowed to fully participate. Participation is a major commitment, and, for all participants, time and financial resources can be prohibitive to full participation. A grant program is offered by the federal government to help individuals and groups off-set the costs of participation.

Economic Benefits

If approved, the proposed coal mines would benefit the local economy around Crowsnest Pass for approximately 25 years while the mines are operational. Economic effects are estimated in Environmental Impact Assessments, which are submitted to the Government of Alberta and Government of Canada. The Benga mine is the only one that has reached this stage so far and is therefore the only mine with economic impact information. Benga estimates that 385 long term jobs would be created, creating $140 million and $210 million in provincial and federal corporate income taxes, respectively. Benga estimates that $195 million would be paid in provincial royalties over the twenty-three-year operating life of the project, with an assumption of $140/tonne average real price of coal. They also estimate $1.5 million would be paid annually in property taxes to municipal governments, which would help growing communities meet the increased demand for water and sewage services. Benga also notes that the mine would bring people to the region to work, thus growing the population and likely increasing both the number and diversity of businesses servicing the community.

The Coal Association of Canada estimates that the coal industry adds billions to the Canadian economy each year. Specific information about Southern Alberta is not yet available.

Key Environmental Challenges

Water Quality

One of the main concerns regarding coal mines is the potential for contamination of our water sources. Mining companies intend to impound all waste water on-site and treat it so that it does not harm the environment. However, because the mountains are steep and can receive heavy precipitation and snowmelt runoff, these impoundment structures can fail. If they fail or are not operating as expected, contaminated water and sediment is released into nearby creeks and rivers. Of the known issues, selenium, nitrate and sediment contamination are the most concerning in regard to water health.

The issues of water contamination are being experienced just across the provincial border on the western slopes in British Columbia by Teck. Teck currently operates a complex of five mines near Elkford, Sparwood and Fernie, and have an active application to open a sixth. The severity of water contamination is perhaps best represented in the hundreds of millions of dollars Teck is spending on water treatment processes.

While Teck has made progress and their latest treatment process is showing promise, finding a reliable and effective solution has been a challenge. Currently, a scientifically proven solution to deal with water contamination of this type and at this scale does not exist. Teck is in the process of building a new water treatment facility in eastern British Columbia, which is scheduled for completion in late 2020. The new facility should help reduce selenium and nitrate contamination of nearby rivers. The American Environmental Protection Agency is also watching and demanding Canada act more responsibly. The contaminated water from Canada flows into the cross-border Koocanusa Reservoir and eventually into other US rivers. A Selenium Modelling Framework has been established to model the long term effects as selenium builds up over time in water.

One of the key questions is whether selenium and nitrates produced as a result of having a mine in the eastern slopes of Alberta would be diluted enough by the Oldman Reservoir to buffer the negative impacts to all those who live downstream. While we currently do not know the answer, we can look at the Koocanusa Reservoir downstream of the Teck mining complex for an indication of what we would expect if the aforementioned mining projects are approved. A recent study by the US Geological Survey found elevated levels of selenium and nitrates in the Kootenai River, downstream of the Koocanusa Reservoir. However, further downstream from the mine it was found that levels were much lower—sometimes even below scientific guidelines for flowing water—than they were immediately downstream of the mining complex, thanks to dilution. When considering and extrapolating this example to our situation in Alberta, it must be considered that the Koocanusa Reservoir is substantially larger than the Oldman Reservoir. Our water system also has different dynamics than that of our neighbours, so we do not know exactly how water quality downstream on the Oldman River would be affected, along with the those who rely on the water for daily use, agriculture, industry, and habitat.

The University of Lethbridge is also planning a study which will look at how to reduce selenium and extreme water hardness in our region. They are in the process of hiring several graduate students to complete this work.

Fish

Too much selenium in a river is known to cause deformities and reproductive failure in fish. In March of 2020, Teck completed a study of fish health near their work sites and found major declines in fish populations living immediately downstream of their mining operation. Some fish species, like westslope cutthroat trout and bull trout, are already at risk of extinction from Alberta so this added challenge could be a serious problem for their survival.

Selenium is also known to cause health problems for humans, however, fish act like the “canary in the mine” as their tolerance to selenium is much lower than that of a human. Much like invertebrates in the headwaters, fish are an indicator species for water health.

Habitat Loss and Linear Footprint Density

Open-pit coal mines require complete de-forestation and removal of all vegetation, small creeks, and intermittent streams on-site. This means that all of that habitat for aquatic species and terrestrial wildlife must be removed until the mining company closes the operation— and hopefully—reclaims and restores the land. The Benga and Montem proposed mines are on existing mine sites that were not properly reclaimed after their initial closure and there has been a long history of industrial developments being abandoned and not reclaimed in Alberta.

Linear footprint density (a standard measure of all the roads, trails, pipelines, etc.) is a concern in the mountains because fish and wildlife populations, as well as water quality, tend to decline as the linear footprint density increases. Many kilometres of new roads are already being built for coal exploration and more would likely be needed if mines become operational. New rail lines would also be required to load and transport the coal, in a region that is already above the density thresholds for healthy fish and wildlife populations.

The Alberta Energy Regulator (AER) is required to abide by the Livingstone and Porcupine Hills Land Footprint Management Plan. This plan sets limits on linear features density and is legally binding within the South Saskatchewan Regional Plan (SSRP) regulations. Alberta Environment and Parks and the AER are working to finalize a “cumulative effects management decision-making tool” that will identify the current linear features density (in relation to the regulatory limits) and how newly proposed projects would impact the density.

Water Quantity

The Oldman watershed has been closed to new water licenses for years because the available water has already been allocated. Thus, any new coal mine will likely need to purchase an existing water license from an existing license holder in order to access the amount of water required to mine and process coal. Another option is an existing industrial allocation held by Alberta Environment and Parks from the Oldman Reservoir but it is unclear how much water is available versus how much is required for these proposed mines throughout their life cycle. While it is impossible to predict potential impacts on water quantity without more data, the fact that the Oldman watershed is semi-arid and prone to extreme weather events, indicates that drought and flood should be a concern for mine sustainability.

Impacts on Key Sectors

Municipalities

Well over 111,000 people live directly downstream from the proposed coal mines. The risk to their drinking water supply caused by a new coal mine is difficult to predict without more research and detailed computer modelling. Looking again to our neighbours in BC, it is concerning that Sparwood had to close down one of its water wells because of selenium contamination from nearby coal mines. Water treatment plants along the Oldman River are not currently equipped to easily remove selenium, although they do have the capability to remove nitrates. Unlike British Columbia, Southern Alberta does not have other rivers or lakes nearby to draw water from in the event that an alternative source is needed. The Oldman River is the only option for several municipalities, and as such, any who rely on it as a water source are particularly vulnerable to potential upstream contamination.

Agriculture

Downstream of these proposed mines is one of Canada’s most valuable agricultural regions. Throughout the Oldman watershed, we use water for primary industries including the irrigation of specialty crops, food processing, and livestock production. Contamination of the water supply—or even a perception of dangerous or unhealthy water—would create a new and significant challenge for the agricultural industry, which is the foundation of our current economy. Farmers, irrigation districts, and taxpayers have invested hundreds of millions of dollars in agricultural infrastructure, research, and technology. If water contamination led to the loss of some agricultural production in Southern Alberta, this would have a negative impact on the livelihood of local residents, as well as the economy of Alberta.

Conclusion

As a community, it is up to us to decide how we address these proposed open-pit coal mines in our headwaters. Some of the potential liabilities of mining operations are clear, but the decision is not easy, as it affects so many people in many different ways. For example, hundreds of jobs would be created by these mines which would directly support small towns and individuals that need work and the investment in their communities. Alberta’s provincial economy is also struggling and these mines would add millions to the overall economy and bring tax revenues to all levels of government.

At the same time, the environmental damage and possible long-term water contamination is of significant concern. We can observe that Teck is facing substantial and currently-unsolved water quality challenges right across the border in British Columbia. We can see what could happen here if the water treatment processes do not perform as expected. Until there is long term scientific evidence that water treatment processes are proven and safe at a large scale, any new mine in our headwaters is a potential liability for fish, municipalities and the agriculture industry.

As each of us struggles to make our own personal decisions about what we think is best for our families, let’s engage with others respectfully, listen to those who have a differing point of view, and engage in responsible discourse to choose what is genuinely the best decision. You are welcome to–and encouraged–to share your views with your provincial and federal elected representatives.

The follow-up to this blog is now available. You can read it here.

Coal Mining in the Oldman Watershed