Panel Secretariat Grassy Mountain Coal Project Impact Assessment
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Panel Secretariat June 11 2020 Grassy Mountain Coal Project Impact Assessment Agency of Canada 22nd Floor, 160 Elgin Street Ottawa Ontario K1A OH3 Dear Madam/Sir: I am opposed to the Grassy Mountain Coal project but would yield to The Citizens of Crowsnest Pass, with one caveat —Selenium. This element gets into our river systems when mining exposes coal to the atmosphere and the attendant moisture. Washing coal also leads to selenium leaching into nearby drainages. Gold Creek and Blairmore Creek Headwaters are right in the Grassy Mountain Coal Project backyard and could easily carry Selenium into The Crowsnest River and the Oldman River systems and thus the Saskatchewan River. Similarly, nearby Daisy Creek drains into Racehorse Creek and the Oldman River upstream of the Gap. Not good. Fording Creek in BC used to be a wonderful Western Cutthroat fishing stream. I fished it several times and had lots of fun and good Cutthroat fishing. Its' current status as a result of Teck's Greenhill mine are detailed in the enclosed Narwal publication dated Dec. 4 2018 which examines Selenium from coal mines in The Elk River System. The adverse effects of coal mining and selenium in this wonderful stream is absolutely appalling. Also enclosed is a Yale University 360, article on selenium, coal mining, and the Elk River. As a Canadian I am ashamed over what we are allowing to happen in our neighbour's waters, as detailed in the also enclosed Yale 360 report. We simply cannot take a chance on continuing with this debacle. My grandparents settled on the Oldman River downstream of Lank's Bridge in the 1894 and doubtless fished Cutthroat in The Oldman. I have fished those same waters with my grandsons for Cutthroat and sure hope they are able to teach their G Sons to fly fish there, as I did them. I have fished every Wed during the Cutthroat season in local and BC waters for about 10 years and so have learned a little about the value of these rivers and streams and the need to protect them and thus The Western Cutthroat Trout which is a precious, delicate, fragile, and extremely valuable asset. Pure strains of this trout are not abundant, as they hybridize with Rainbow trout giving reasons why we must protect streams like the Oldman and Fording, that have pure strains due to the fact that there are natural barriers to the Rainbows in those streams. As a matter of interest, and to underline how fragile the Western Cutthroat are: when Eastern Speckled Trout were introduced to Cutthroat waters, The Speckled Trout takeover due to the Speckled maturing sexually significantly earlier than the Cutthroat. They out breed them and in time will wipe out The Cutties which is happening, or has happened, in Cataract Creek. Speckled Trout are not native to our streams, we got them out here by tampering with nature, which is exactly what strip coal does mining does in this part of Canada. We know two things about Selenium with certainty. One -- it leaches into river systems and kills Cutthroat Trout and damages rivers' ecosystems. Two -- there is no known or proven way to mitigate the Selenium poisoning. How in good conscience could we allow Grassy Mountain to proceed, before we have solid proof of the resolution of this Selenium issue? Respectfully yours: 1 <Signature and personal information removed> r fp/4ft 16 , 1 e• — • e#""'te. •••• •—•"'".1.• • - - a _ • "kite mmiur c. alp .•''' 0 Tr w. * Ilut • For decades B.C. failed to address selenium pollution in the Elk Valley. Now no one knows how to stop it. There are no viable solutions to stop the tide of selenium leaching into Canadian and U.S. water from a 100-kilometre stretch of coal mines owned and operated by mining giant Teck Resources. Deformed fish, a potential fish population collapse and contaminated drinking water signal more trouble to come Carol rinnitt • Dec 4, 2018 ©17 min read If you follow the crystalline waters of the Fording River up the Elk Valley, past Josephine Falls, you'll discover a small pocket of genetically pure westslope cutthroat trout prized by fly fishers from around the world. The species is known for sparse, dark freckles that run along the contours of an arched back and the signature orange-pink slits that gouge both sides of its throat. Small teeth line the entirety of its mouth, even under the tongue. "Cutties," as they're affectionately referred to in the bustling fly fishing shops in Femie, are thought to be one of the first fish species to populate British Columbia after the last ice age. Now found in only in a small fragment of its historic habitat, the species is widely understood to be an indicator of ecosystem health. Pacific populations are currently listed by the federal government as a The meandering oxbows of the Upper Fording have created the unique conditions for this particular population of westslope cutthroat trout to remain genetically distinct, not having bred or 'hybridized' with other nearby populations. Yet these very same gentle waters now threaten to bring an end to this particular lineage of westslope cutthroat trout, first noted in the journals of Lewis and Clark and christened with the scientific name Oncorhynchus clarkii kwisi -rt - . 4 114,' • r s'•40".tr' J. ,.4 _ II 7 .?? .1 • 6,•• • • _ • ...SOP a • '1, .-,....gz•. b, k .,;-- .. • • - ., 0. ••,- -,0-..-..,giV'ff. -: e. 4.Iii . _ '. 41 ; I. 4 tit -• 11-6 dyk • 4;• 4 : -4' 7. 4; •7•40%,- 1 :44 4,01 The Upper Fording River. where high levels 0 selenium have been measured. is closed to fly fishing The river is the namesake of Teck Resources Fording River coal mine Photo Jayce Hawkins / The Narwhal "It or- • 41... • • lor `1, oiln` --rib el% EP - A westslope cutthroat trout caught by Ryland Nelson in the Elk River and is likely not genetically pure According to Canada's Department of Fisheries and Oceans. Indigenous species of these trout are criticaIiy important to protect as they "may be required for attempts to re- establish extirpated subpopulations. and the future preservation of the species as a whole.' Photo Jayce Hawkins I The Narwhal Selenium pollution, leaching from manmade mountains of waste rock, has inundated the waterways of the Elk Valley, depositing itself in the docile currents of the Fording and Elk Rivers. "We've got westslope cutthroat trout and bull trout throughout the lower reaches of the Elk River," says Lars Sander-Green, an analyst with the local conservation group Wildsipll . "The fish are basically concentrating that selenium both in their tissues but, more importantly, in their eggs and in their ovaries that will cause birth defects and reproductive failures." Standing beside a snowy bend in the Upper Fording River, Sander-Green explains how selenium builds throughout the food chain, First, it settles in slow moving waters where it is converted into organic compounds by bacteria. It is then taken up by algae which are eaten by bugs which, in turn, are eaten by fish. "The main concerns people have with selenium are mostly about the fish," says the unassuming, soft-spoken analyst with a degree in physics and a penchant for data sets. As the contaminant accumulates in trout it can lead to ghastly facial and spinal deformities, an absence of the plates that overlay and protect the fish's fleshy gills and —where deformities make survival impossible — death. In 2014 an expert report prepared for Environment Canada warned that selenium pollution from mining in the Elk Valley was negatively impacting fish. The report warned that increases in selenium pollution would inevitably lead to "a total population collapse of sensitive species like the westslope cutthroat trout." INN II Am' In these 1960 photos. Dr Lemly. an expert asked to prepare a A westslope cutthroat trout with a missing gill plate, a telltale report on selenium pollution in the Elk Valley for Environment deformity caused by selenium poisoning This trout was caught Canada, details spinal deformities of mosquitofish (left) and a in 2014 in Coat Creek a tributary of the Elk River. Photo: red-horse minnow (right) as a result of selenium poisoning in Environment Canada North Carolina from a coal-fired power plant Photo A D Lemly / Environment Canada • • t 4•- •-•ffle- ■ ••• • .1*".441111111 , 4 • ‹-RAzeici?„, STTiti • -••• !,t ••••4— - - "or 44 ••• • • • • Waste rock deposits cover a massive section of land at the Fording River coal mine Photo Jayce Hawkins / The Narwhal gal it Off" r Westshore Terminals is the largest export facility for coal on the west coast of North America. Westshore ships 19 million tonnes of metallurgical coat each year for Teck Photo: Carol Linnitt / The Narwhal "With this kind of coal mining, open pit or mountaintop removal, there's a lot of rock between the mountain and the coal," says Sander-Green, hands tucked into his pockets and shoulders slightly gathered about his neck in an effort to fend off the unseasonable October cold. "You blast that and truck it over to the next valley, they fill in the mountain valley with this waste rock...and with coal, often there's some selenium in the rocks...The water trickles down and slowly leaches selenium out of those rocks. It ends up flowing down into these bigger rivers like the Elk and Fording Rivers all the way down into Lake Koocanusa [a reservoir created by Montana's Libby Dam]." Teck coal mine _ fording River ■ Town Fording River • Greenhills Elkford ne Creek Sparwood Ukview 13k Rivoto Femie Coal Mountain Lake KOOLarIllcit British Colombia U.S.A.