Letter to the Parliament of Canada re: Grassy Mountain Coal Project
To the Honorable ______________,
(Insert a short personal blurb about your connection to the affected area).
The decision to rescind the Alberta Coal Policy has opened almost 1.5 million hectares of protected Zone 2 lands to open-pit mining for coal was done without public consultation. The coal policy that was originally put in place by Peter Lougheed’s Progressive Conservative government after extensive consultation. In announcing the changes, the Provincial government implied that there would be no substantial impact because land use plans under the province’s Alberta Land Stewardship Act would provide new regulatory protections. But only one of those land use plans is complete and it calls for retention of Coal Policy protections until more detailed area plans have been completed. These updated plans have yet to be started and the removal of the Coal Policy does, in fact, open up vast new areas of Zone 2 lands to coal mining. This is made obvious by the current proposal. I am deeply opposed to any such development before extensive consultation with First Nations peoples, affected communities the length of the affected watersheds, environmental specialists, and economists.
As unoccupied Crown Land, Indigenous treaty signatory nations have continuing rights associated with this land. This particular area of unoccupied Crown Land is covered under Treaties 6 and 7, and the duty to consult Indigenous communities in advance of major land use changes is well established in the Constitution and through subsequent court decisions. The Provincial government did not meaningfully consult with Treaty First Nations or with Metis Associations before effectively opening their hunting, medicine gathering and sacred places to coal strip mining.
The Eastern Slopes of the Rocky Mountains are the source headwaters of the Oldman, Bow, Red Deer, North Saskatchewan, Athabasca and Smoky Rivers. Water is a crucial strategic issue in the Canadian prairies and has been since before Confederation when these headwaters were first protected by the federal governments of the day. Our small rivers sustain countless cities and towns and more than 2/3 of Canada’s irrigated farmland, as well as much of our agri-foods industry. But all the historically-available water in the South Saskatchewan basin has been licensed already and there has been a moratorium on new licenses since 2006. Strip mines and associated roads and infrastructure will have the effect of impairing hydrological function and polluting runoff. At scale, this is bound to lead to increased spring flooding because of surface diversion of snowmelt and spring rains, increasingly severe summer stream droughts because of depleted groundwater aquifers, and increased contamination of water at all seasons. And of course this is all in a climate change context: projections are for increased frequency of severe precipitation events and reduced water supply that will only magnify the damage from stripping the land.
Species at risk whose habitat may be lost or severely impaired by strip mining of coal in the Eastern Slopes include grizzly bear, woodland caribou, white bark pine, limber pine, westslope cutthroat trout, bull trout and Athabasca rainbow trout. Climate modelling has shown that the streams that will be impaired by coal mines planned for the Oldman River watershed are the best cold water refugia left for the aforementioned fish species anywhere in North America under likely climate change scenarios. Those are the streams now at risk in that part of the Eastern Slopes. Strip mining doesn’t just affect stream channels; it destroys the hydrology of headwater basins that those streams rely on for groundwater base flows. It also contaminates surface and groundwater with selenium, nitrates and other salts and metal oxides that can be toxic to fish, livestock and humans. The best effort to control selenium pollution to date has been by Teck Resources in southeastern BC. Their efforts have failed dramatically, most recently resulting in the death of over 90% of the threatened westslope cutthroat trout population in the Fording River.
Much of Zone 2 has been leased now. Once leased, and absent the restrictions in the former Coal Policy, companies have a right to explore for and delineate the coal resource. They are actively doing that now. Issuance of a lease does not assure development rights, but it does anticipate them. The volumes of coal currently under lease are staggering. Whether thermal or metallurgical, it is all subsequently oxidized, which releases carbon dioxide into the atmosphere and particulates into the air. Coal is coal. Canada may not be legally responsible for carbon impacts from combustion that occurs in other parts of the world, but if it’s coal originating in Canada, we certainly have a moral responsibility.The Government of Canada and Alberta are subject to international agreements to reduce greenhouse gases as per the 2016 Paris Agreement. This is an urgent priority in the face of our ongoing climate crisis and the federal government has a duty to consider the impact of major new initiatives on our ability to meet our greenhouse gas reduction targets. Enabling coal combustion for electricity, steel-making or whatever other purpose slows the search for and transition to non-carbon alternatives.
Given the potential impacts of this decision, I am appalled at the decision of the Alberta Provincial Government to rescind the Alberta Coal Policy which was carefully crafted to protect the Eastern slopes. I beseech the Federal Government to step in and exercise jurisdictional responsibilities that are affected both by individual coal mine proposals and by the Alberta government’s decision to open up formerly protected lands to new strip mining. The Federal government has both the responsibility and the power to intervene — and no political reason to avoid intervening.
Sincerely,
