Panel Secretariat June 11 2020

Grassy Mountain Coal Project

Impact Assessment Agency of

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 , 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 r fp/4ft 16 , 1

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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.

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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

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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

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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

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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]."

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Teck's five metallurgical coal mines are all upstream of the transboundary Koocanusa Reservoir. Graphic Carol Linnitt The Narwhal • 411

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The confluence of the Elk and Fording Rivers Photo: Jayce Hawkins / The Narwhal

The expansive waste rock piles filling in low-lying areas of the Elk Valley are exposed to air and water — the elements necessary to move selenium — all year round. The result is a monumental selenium spill in slow motion.

Selenium is a naturally occurring element and is in very small doses but can become toxic at higher levels. It is harmful to aquatic life and other egg-laying creatures, even at low levels.

In order to safeguard aquatic life, recommend selenium levels not exceed two parts per billion. Those same guidelines limit selenium in drinking water to 10 parts per billion. In the U.S., the Environmental Protection Agency's guidelines set safe limits for aquatic life at 5 parts per billion.

Measurements taken throughout the Elk Valley have found selenium levels at 50 or 70 parts per billion. In many cases, levels are higher than 100 parts per billion. (A 2013 study found selenium levels in rivers upstream of the mines at 1 part per billion).

Yet the B.C. government continues to sanction the expansion of Teck's mining operations, despite a failed water treatment experiment by the company and a distressing new problem: the contamination of drinking water.

Private wells on local farms and a municipal well in the district of , home to many of the miners working at Teck's operations, have been after showing selenium levels higher than 10 parts per billion, well in excess of what is considered safe for human consumption.

Doug Hill, regional director of mining operations with the B.C. Ministry of Environment, says exceeding B.C.'s water quality guidelines for selenium is not enough of a reason to slow down mining activities.

We're already over our numbers that we want to see," Hill says in an interview, before issuing a quick reminder: "Our water quality guidelines, they're not law in and of themselves. They are used as benchmarks to assess the impacts of mining projects on water quality."

Asked if he anticipates more contaminated sources of drinking water, Hill hesitates,

"I couldn't say that we're at a point now with our groundwater monitoring that we could accurately predict that." Bill Hanlon, a local horse breeder and conservationist, manages a property just outside of Sparwood that is a popular destination for hunters seeking proximity to game in the Elk Valley, which is class one bighorn sheep winter range. The private well on that property is contaminated.

Bill Hanlon a local guide and conserrationM, is worried too Hanlon wants to see a better balance between environmental much selenium ir. the Elk Valley ecosystem may take the river to and economic interests in the Elk Valley and argues despite the a 'tipping print' Photo Jayce Hawkins (The Narwhal problems with selenium he believes Teck works hard to be a good neighbour and has helped created protected areas to offset the impacts of miring Photo Jayce Hawkins / The Narwhal

"This property here has some of the highest selenium measurements. They test it regularly," Hanlon says.

The property is on the opposite side of the river from the coal mines, prompting Hanlon to ask, "... why is the selenium going this far out in the gravel bed river system?"

Hill says Teck conducted a 2017 groundwater study, currently under review, that will be used by the company to create a "conceptual model" for how groundwater flows and moves throughout the valley.

"It's complicated," Hill explains. "The geology there isn't simple to understand. The selenium is going to behave differently in groundwater than in surface water."

Hanlon, who is also the chair of the British Columbia Backcountry Hunters and Anglers, says he's worried by proposals for three new coal mines by three new companies in the Elk Valley. "If we lose this river, if it tips...there's a lot of livelihood based on this area and on the river itself."

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Fernte airbnb manage' and fly fisher. Ryland Nelson. The clear- cut iougirg that we see on the Hi:skies that's a lot more in people's lace but this selenium issue is you know it's silent and it is much, much bigger of an issue to the health of this watershed' Nelson told Tim Narwhal Photo Carol Lionitt The Narwhal "It's not just the coal mines, it's cumulative effects and I fear we're getting near a tipping point in terms of a balance of a healthy environment and a healthy economy. We don't seem to know when to quit."

University of Montana biologist Erin Sexton began studying selenium in the Elk Valley nearly two decades ago when the wildlife-rich Flathead Valley, next to the Elk Valley, was being eyed by coal companies. Mining and oil and gas development are now permanently banned in the Flathead Valley.

"We came up to the Elk River in B.C. from Montana in the early 2000s to collect data," Sexton recalls during an interview. "We were surprised by what we found."

Sexton said she and her colleagues expected the Elk Valley river system to be impacted by mining, but they did not anticipate the extent of the damage they encountered.

"The issue with selenium is that it's what we call biphasic, meaning that it goes from good-for-you to toxic in a really tiny window," she says.

Of particular alarm for Sexton was the near absence of macroinvertebrates, the little bugs — mayflies, stoneflies, caddisflies — that feed the local fish populations.

"We're losing certain species of those very important macroinvertebrates. Ones that are more sensitive to pollution are disappearing and we know they should be here because we found them in the Flathead which is very close," Sexton says. "Rather than this rich diversity...we found just a few species in the Elk River."

To the alarm of Montana officials, Lake Koocanusa, fed by the Elk River, is showing signs of increased selenium pollution.

Sexton says selenium contamination is acute directly downstream of the mines. "Whereas further down in the reservoir and in the system, [the effects] are more chronic and will take place in a longer timeframe." She adds that the overall effects of selenium poisoning can be hard to identify, despite seeing deformities in fish in the Elk.

"It's kind of a hard problem to detect because the ultimate impact of selenium toxicity is a failure to reproduce so if you're not seeing those fish in the system, then how do you know that they're being impacted by selenium?"

In an effort to determine the extent of selenium contamination, one day in October Sexton and colleagues from B.C. and Montana conservation groups hop into a flotilla of canoes, using GPS coordinates to locate the spot in the Koocanusa reservoir where Teck has done water sampling.

Erin Sexton Leads a group out on to the Koocanusa Reservoir to conducting independent water testing. Photo Jayce Hawkins / 1 he Natwhat Once the canoes are in position, Sexton takes numerous water samples, using standardized methods developed by the U.S. Environmental Protection Agency.

"Basically, we'll send it back to the lab with a duplicate and then see what we get back," she says.

Teck and the B.C. government conduct regular water testing, but the raw data is not made available to the public. Some areas, like this particular spot on Lake Koocanusa, aren't tested year round.

The reservoir can freeze and experience a drop in water levels, creating dangerous cavernous conditions under the ice. It's a barrier to winter water testing, an important time to test for selenium because low water levels can mean a higher concentration of pollutants, says Sexton, who is among a growing chorus of Montana voices expressing concerns about selenium pollution from Teck's mines crossing the B.C.-Montana border.

Last July, two U.S. representative on the International Joint Commission, a Canada-U.S. body that oversees a treaty to protect transboundary waters from pollution, went public with criticism that their Canadian counterparts were 5u nor essing scieue on the health impacts of selenium and relying on out-of-date data rather than on more current studies for an upcoming commission report. The commissioners warned that Teck may not even have the technology necessary to stem the tide of selenium moving from the Elk Valley mines into U.S. waters.

Michael Jamison, senior program manager with the National Parks Conservation Association in Montana, worries that contamination flows directly south, where he lives with his family. What's happening downstream is bad enough, says Jamison, "but then when you look upstream at what's happening in B.C. —polluted air, contaminated fish, and wildlife — I don't know how they handle it...it's so acute on the northern side of the border."

Jamison is perplexed by the unabated pace of mining in the Elk Valley, despite pollution levels well above B.C.'s guidelines. In the U.S., companies would never be granted new permits if they were found to be hi violation of permit levels, he says. There are also other important differences between industrial operations in B.C. and those south of the border, Jamison notes.

"We have an Endangered Species Act in the U.S. that doesn't really have a counterpoint in B.C. We have enforceable requirements around wastewater discharge and remaining within the parameters of your permit. Those presumably exist here...it seems like in the U.S. we have rules written in ink, maybe up here they're written in pencil with an eraser handy...'we'll adjust the permit.'"

Even if Teck's Elk Valley operations halted immediately, Jamison says the problems they have created will persist for hundreds of years, likely long after the company ceases to exist.

"These piles of waste, they're going to be leaching selenium into that system for 700, 1,000 years. Teck's not going to be around in 1,000 years."

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Some the many waste rock pies that lire coat mining operations all ttlooghok.t the E tk Vaiey. Photo .ayce Hawkins I The Narwhal Hill confirms that Teck's Elk Valley operations are monitored under a valley-wide permit that has short-, medium- and long-terms selenium targets established under the Flk Valley Water Quality Plan. He agrees that selenium pollution from Teck's mining operations is a long-term problem.

"These legacy waste rock piles there are going to be leaching sulphates and selenium for years to come, regardless of what happens to the mines right now," Hill says. "It's going to take long-term sustained action before we see really remarkable changes to water quality."

The water quality plan established in 2014 focuses only on attempting to stabilize selenium levels in the water until 2023, Hill explains. B.C. does not anticipate that Teck will begin the work of lowering selenium levels in the watershed until the 2030s.

But just how that will happen isn't clear. Teck introduced a $600 million water treatment plant in 2014 that proved problematic from the start. The plant caused a fish _, six months after coming online. In 2017, the plant was taken offline after it was revealed that the treatment process was releasing a more bioavailable form of selenium into the environment, meaning it was taken up more readily by biotic life.

Teck said in a statement that the struggling water treatment facility at its Line Creek operations has been recommissioned and is now back in operation. A second water treatment facility is currently under construction, Teck spokesperson Chris Stannell wrote in an e-mail to The Narwhal,

Teck expects to invest between $850 and $900 million in water treatment facilities over the next five years and is experimenting with' ' methods in an attempt to reduce the amount of selenium entering the environment via waste rock piles, Stannell says.

Teck Resources, which posted profits of $6.1 billion in 2017, was the single largest donor to the BC Liberal party. The practice of corporate political donations has since been

Hill acknowledges there have been significant "setbacks" in Teck's water treatment plans.

"There's a lot of different parts and piece to this project and whilst there might be setbacks in one particular area — albeit a really important area, which is the treatment technology — I think we need to continue to plug on and move forward to make this plan work."

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A waste rock dump spans kilometres at a Teck Resource's mine Waste rock piles, exposed to the element and growing every day. are what release selenium into the local environment Rain and melted snow will carry the contaminant into nearby creeks and rivers Photo: Jayce Hawkins / The Narwhal

Selenium is often found in coal rich deposits like those underlying much of the Elk Valley, where Teck Resources owns and operates five sprawling metallurgical coal mines. To get at those blackened seams, Teck employs a technique known as cross-valley fill, a bucolic euphemism for mountaintop removal mining.

The mines, easily visible in satellite imagery, are staggering in their scope. Mountains are cut down and blasted into terraced slopes that are slowly separated into piles: marketable coal and spoil. Anything not deemed to be of commercial value is trucked by heavy hauler out to piles that eventually grow into jagged black pyramids — manufactured shapes that do a poor job of mimicking the former mountainsides.

Teck Resources is the world's second-largest exporter of coal for use in steelmaking, with much of the resource making its way by train to the Westshore Terminals beside the familiar docks of the Tsawwassen ferry. Teck's Elk Valley mines are some of the largest in Canada — and are poised to expand, despite rising concerns about their growing impact on fish and drinking water.

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Teck Resources' GreenhIlls mine In British Columbits Elk Valley. CREDIT: GARTH LENZ

From Canadian Coal Mines, Toxic Pollution That Knows No Borders Massive open pit coal mines in British Columbia are leaching high concentrations ofselenium into the Elk River watershed, damagingfish populations and contaminating drinking water. Now this pollution isfl owing across the Canadian-US. border, threatening the quality of U.S. waters.

BY CHLOE WILLIAMS • APRIL 1, 2019

aul Samycia was in a boat floating on British Columbia's Elk River when he reeled in a P strange-looking trout. One side of the fish looked like any other cutthroat trout — black speckles, orange belly, olive back. The other side of the fish had a hole in its face. Its gill cover, the flap on the side of its head, was partially missing.

Samycia snapped a photo of the fish. For the last four years, Samycia, the owner of Elk River Guiding Company, a fly-fishing shop and outfitter based in Fernie, British Columbia, has been collecting photos of misshapen catches. Some have shortened gill plates. Others have snubbed noses, making them look like they swam into a rock. He and fellow guides have amassed nearly 4o photos.

Samycia started noticing the deformities about to years ago, but the sightings are becoming increasingly common. Scientists have found substantial evidence that the cause is selenium, a trace element, leaching from coal mines in the Elk River watershed. A 2013 study found heightened selenium concentrations downstream of mines in the Elk Valley, and a 2014 report linked high selenium to a slew of damaging ecological consequences in the river, including malformations and reproductive failure in fish. Environmental groups now are raising concerns about harm to the ecosystem, ranging from the Elk River's tributaries to waters downstream that cross into the United States. They also point to risks for human health in communities nearest to the mines, where selenium is contaminating drinking water. Meanwhile, tensions on both sides of the border are escalating: U.S. members of a binational water regulator sounded alarm bells last year, charging that Canadian members were suppressing scientific evidence related to the selenium pollution and its risks to the ecosystem and human health. The situation in the Elk has been called "a monumental selenium spill in slow motion."

"We have one of the biggest selenium contamination issues in the world taking place in the Elk River," says one biologist.

The destructive consequences of selenium pollution are well documented in North America. In the 197os, agricultural runoff carried high selenium loads into a reservoir in California's San Joaquin Valley, causing deformities in fish, reptiles, and birds. In the early 2000s, a vast mountaintop removal mining operation in West Virginia wrecked ecosystems in the Mud River. The problem in the Elk Valley is one of the most current and pressing examples. "We have one of the biggest selenium contamination issues in the world taking place in the Elk River," says Erin Sexton, a biologist at the University of Montana who has been studying the region for nearly 20 years. It's also one of the few cases to extend beyond borders. Now, scientists, conservation groups, industry, and government organizations from both Canada and the U.S. are trying to find a solution to one of the most complex, far- reaching selenium leaks either country has ever seen.

The Elk River begins its journey in the and flows southwest for 140 miles through meandering oxbows before reaching Lake Koocanusa and the Montana border. Miners have excavated coal from the Canadian side of the watershed since the i800s. In the past 4o years, large-scale, open-pit mining has come to dominate the region — a technique that involves stripping away layers of rock to get at coal deposits deeper in the earth. 3 .4 . • a 4, fee .. .410 op 1111,0 %.• • •• 4*4•••- ., c ,,, 0 11• •• „. • A • -,6 • • • IP r as*, • 4 . 1 9 6 • ir • ..•/* • ., . • . • ' 4 II': .4 • • •-.• •. - •• • • t 4 . .6 f 1 4 -•,.• 10 • 6' p ' ... • 1 4 • ff.. , )t ••••• • • tv ,. ••• . ••es 1,146 k j . 111 4 fb_ p • N os : 41, I ‘'' ' •-,4 s, . • ••, . • . 64 11 • •• . 1/ • 1 411. •• $ : 4 g 1? • I 4 4 4P • • B A • II P s so 1 I § •• •••o s . 4 . • • • •4 6 • 'IP gp . • •• • • 4 • • ‘• • % '4, • .• 4 • • 4 • • • a

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A deformed cutthroat trout with its gill cover missing, found in the Elk River downstream of several major coal mines. COURTESY OF PAUL SAMYCIA

Teck Resources, a Canadian mining company and the world's second largest exporter of steelmaking coal, operates five open-pit coal mines within the watershed. These mines are some of the biggest in Canada. Together, they have the capacity to produce more than 21.7 million tons of metallurgical coal, an essential ingredient in producing steel from iron ore. To get at the coal, the company uses a technique called cross-valley fill, which in practice, looks a lot like mountaintop removal mining. Workers dig into hillsides, creating massive, terraced craters - holes so big they make 55o-ton trucks look like toys. They separate the valuable coal from the unwanted rubble and dump the debris into waste piles throughout the valley. Scratching away at the surface day and night, the company has moved enough earth to flatten mountains, all while filling valleys with massive heaps of rock.

The piles of rubble are the source of the selenium problem. The trace element is naturally occurring and often accompanies the same geological formations as coal. When exposed to water and • air, the element seeps out of rock and soil. In small amounts, ALSO ON YALE E360 selenium is necessary for biological function. At higher Leveling Appalachia The legacy of mountaintop removal concentrations, however, it can become harmful. That's the mining. Watch the documentary. "paradox of selenium," says Dennis Lemly, a retired selenium ecotoxicology expert who used to work as a researcher for the U.S. Forest Service and Wake Forest University in North Carolina. "Just a few times more than is required for normal health can be toxic." In humans, chronic exposure to high selenium concentrations can cause nausea, fatigue, skin lesions, and neurological disorders. In other animals, the high levels of the element have been shown to cause liver damage, paralysis, and even death. - Borders ER'sling Coal Mines * Proposed Coal Mines Coal Bearing Geology Lake Koocanusa Mapr Streams .1 North Fork Flathead River Watershed I= Elk River Watershed rjr Fording rt.ver

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In Sparwood, a community of 3,490 people less than two miles from one of Teck's mines, selenium in drinking water is reaching concerning levels. The town, located within the traditional territory of the Ktunaxa Nation, pulled one of its water wells offline last spring when selenium exceeded British Columbia's drinking water standard of io micrograms per liter (selenium has been measured as high as 13.5 micrograms per liter, District of Sparwood records show). Last spring, Teck issued a statement warning landowners and farmers that "some mine-related constituents may be elevated!" Company testing found that selenium levels in four private wells exceeded provincial standards. Teck did not comment on the specific selenium concentrations in these wells.

In an emailed statement, Chris Stannell, a company spokesperson, wrote that Teck has worked with governments, scientists, and First Nations to develop a management plan to address the selenium issue and is "dedicating significant resources to taking the steps necessary to achieve the objectives" laid out in that plan.

In the meantime, Sparwood has two other wells to provide residents with clean drinking water, and Teck is now financing the construction of a new well to replace the tainted one, according to Sparwood Mayor David Wilks. The company has also been supplying bottled water to landowners whose private wells contain selenium levels exceeding British Columbia's standard.

British Columbia's guideline for the protection of aquatic life is 2 micrograms per liter. The U.S. Environmental Protection Agency's standard is 3.1 micrograms per liter in rivers and 1.5 in lakes. In the Elk Valley's waters, selenium has been recorded at 5o to 70 micrograms per liter and in some cases, as high as 100 micrograms per liter.

Selenium levels were at least seven times higher in the Elk's waters below mines than above them.

Those high selenium levels have had major repercussions on the watershed, Sexton, of the University of Montana, says. "The impacts are pretty extensive." She and her colleagues conducted one of the first publicly available scientific studies showing that mining in the Elk Valley was detrimental to the river's ecosystems. They collected ecological and water quality data in both the Elk and its neighboring watershed, the Flathead, which is considered relatively pristine.

Sexton was baffled by the differences she saw. Selenium levels were at least seven times higher in the Elk's rivers below mines than above them or in the Flathead, according to a 2013 report she published. The researchers also found reduced algae and invertebrate diversity in the Elk compared to the Flathead — a sign that selenium pollution was killing off sensitive species.

Algae and invertebrates form the base of the food web in a river system. The selenium they accumulate in their tissues gets transferred up the food chain. In fish, the element tends to concentrate in females' eggs, either killing juvenile fish or causing major birth defects. "Then all of a sudden the fish start disappearing, and in a couple of years, they're all gone," says Richard Hauer, a now-retired limnologist from the University of Montana who co- authored the study with Sexton. If you weren't paying attention to the early warning signs, you might not notice a selenium problem until it's too late, he says.

In the Elk Valley, scientists have been paying attention to the warnings. A 2014 review by Lemly, the selenium ecotoxicology expert, details evidence of selenium poisoning in fish, including telltale signs such as twisted spines and cranial deformities. Environment Canada, the federal agency that oversees environmental enforcement, asked Lemly to conduct the review as part of its investigation into selenium pollution coming from Teck's mines. • 4 a. -;t4 • - "4'7 j r••

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The Upper Fording River, a tributary where selenium levels are some of the highest in the Elk watershed. COURTESY OF LARS SANDER-GREEN / WILDSIGHT

Lemly's conclusions were unequivocal: Selenium levels in fish eggs and in surface waters are beyond those known to cause reproductive failure, he writes. In one of the Elk's tributaries with the highest selenium concentrations, the Upper Fording River, he estimates that the element is killing nearly half of juvenile fish — more than i8o,000 fish each year. The Upper Fording is also home to a genetically pure and distinct population of westslope cutthroat trout (Oncorhynchus clarkii lewisi), which is a species of special concern in Canada. Lemly calls the fish a sentinel species. "As they go, the aquatic system goes," he says.

The Upper Fording River is now closed to angling due to uncertainties about the viability of the cutthroat population. Meanwhile, questions remain about health risks linked to eating fish from river. "It's not an area that's being that well researched," says Lars Sander- Green, an analyst with Wildsight, a local environmental group. Although not specific to the Elk watershed, a 2017 study conducted by the Canadian government found that subsistence fishermen and First Nations who eat fish caught downstream from sources of pollution have high selenium blood concentrations. Prolonged exposure to selenium in humans can cause selenosis, a condition linked to hair loss, skin lesions, neurological disorders, and intestinal problems.

A few miles north of the Montana border, water from the Elk River spills into Lake Koocanusa and drifts across the U.S. border to Libby Dam. There too, selenium levels have increased. David Naftz, a hydrologist with the U.S. Geological Survey (USGS), is part of a team collecting samples of water, sediment, fish tissue, and eggs to better understand how selenium moves through the ecosystem. "The large amount of selenium coming into Lake Koocanusa is concerning," Naftz says. There's an influx of upwards of 14,000 kilograms per year — seven times more than Utah's Great Salt Lake where USGS scientists reported selenium in the eggs of eared grebes and black-crowned night herons approaching levels that cause reproductive failure.

Regulating an environmental problem that affects international waters is extremely complicated, experts say.

Regulating an environmental problem that affects international waters is extremely complicated, experts say. In Montana, selenium standards are used to set discharge limits on permits. British Columbia employs a similar scheme. But conservation groups say the system on the north side of the border is broken. "We don't have anything enforceable," Wildsight's Sander-Green says. Water quality guidelines in British Columbia are just that — guidelines, not laws.

The government in 2013 ordered Teck to develop a water quality management plan to address the selenium issue. But according to company reports, Teck exceeded the selenium limits laid out in the plan six times in 2016 and another 20 times in 2017. A 2016 audit shows British Columbia's provincial government granted Teck permits despite getting input from experts that the proposed selenium levels on those permits failed to protect the environment. U.S. commissioners from the International Joint Commission, a binational regulatory body that oversees shared Canada-U.S. waters, have also been critical. In a letter last year, they accused Canadian commissioners of minimizing scientific evidence on the valley's selenium problem and its risk to aquatic and human life.

Sexton says she finds the continuous lack of regulatory response to the selenium issue shocking. "As a scientist, you do this kind of work with the objective that the data you collect will inform environmental decision-making," she says. But mining in the Elk Valley has steadily moved forward, despite mounting evidence pointing to the source of the problem. "From the big picture, it doesn't appear that there is any regulatory response at all," she says. j II W. ---41.1111 — — • ..•••• -••

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Biologist Erin Sexton conducts water sampling In the Elk River. COURTESY OF ERIN SEXTON

The Canadian government is currently working on amendments to federal mining regulations that would place compliance limits on selenium discharges. British Columbia and Montana are also working to set selenium standards for Lake Koocanusa by 2020. Once established, the binational standard would be used to inform discharge limits on permits on both sides of the border. Until then, the Ktunaxa Nation Council, along with other First Nations' leaders, are urging governments on both sides of the border to adopt more conservative interim standards for selenium in the lake.

Teck plans to build six new waste treatment plants by 203o, but currently it has only one, and it had to be shut down at least twice because of technical problems since it came online in 2014. The company is considering other water treatment options too, such as systems that use microbes to remove selenium from water-filled pits. Some question whether those tools are capable of stopping such a massive selenium leak. These technologies have never been used at such a large scale, says USGS's Naftz.

Meanwhile, three companies have proposed new mines in the Elk River watershed. Currently in the early stages of environmental assessment, each new mines would add another 8 million tons of coal production to the valley. Sexton says the area needs a moratorium on mining until technologies have been proven capable of mitigating pollutants. By continuing to issue mining permits, regulators are only letting the problem get worse, she says. But others point out that stopping the mining isn't necessarily going to make things better. "A moratorium on mining without a solution is just a moratorium," Hauer says. The region needs a long-term solution to deal with such a massive, long-term problem.

For now, the mines show no signs of slowing. Trucks continue hauling rock waste to ever-growing piles; trains loaded with coal head toward the coast destined for overseas markets; the people of Sparwood worry about the safety of their drinking water; and ALSO ON YALE E360 fishermen collect photos of deformed fish for their growing file. A new way of understanding what makes a river healthy. Read more.

aChloe Williams is a Canadian freelance journalist, covering energy, environmental health, and neuroscience. Her work has appeared in Audubon, Popular Science., and Spectrum. She lives in Edmonton, . MORE 4 Unique B.C. trout population suffers 93 per cent crash downstream ofTeck's Elk Valley coal mines

Environment Canada was told that selenium pollution emanating from a string of coal mines in B.C.'s southeast corner could lead to reproductive failure and 'a total population collapse' of sensitive species like the westslope cutthroat trout

carol_Lirinitl. • Apr 16, 2020 010 min read

The adult population of genetically unique westslope cutthroat trout in a river in B.C.'s Kootenay region dropped by 93 per cent this past fall compared with 2017 levels, according to a from Teck Resources.

The company operates four giant metallurgical coal mines in the Elk Valley region, where levels of selenium pollution, which originates from the mines' many waste rock piles, have ased

Teck has conducted fish surveys in the Upper Fording River since 2012. A fall presentation from Teck reviewed by The Narwhal shows that monitoring conducted by contractors in September and October 2019 identified a precipitous decline in adult and juvenile westslope cutthroat trout in the Upper Fording and that such a decline "represents a trigger” for a population crash. X

First Name Last Name Email Sexton began studying selenium in the Elk Valley in the early 2000s and was involved in a process that led to the creation of the Elk Valley Water Quality Plan. It is under this plan that the province has continued permitting Teck's mining operations, despite growing selenium pollution.

The plan was informed by a 201 4 rehnrrprepared for Environment and Climate Change Canada by Dennis Lemley, a renowned selenium expert. The report warned that selenium pollution from mining in the Elk Valley was negatively impacting fish and concluded that increases in selenium pollution would inevitably lead to "a total population collapse of sensitive species like the westslope cutthroat trout."

Sexton said she was disappointed but not surprised to see Teck reporting the population drop. "It's déjà vu," she said.

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A meandering bend in the Upper Fording River where high levels of selenium have been measured Photo Jayce Hawkins I The Narwhal

Sexton added it is evident B.C. ignored available science when structuring permits for Teck's Elk Valley operations. Under the Elk Valley Water Quality Plan, the province allows Teck to continue operating its mines as long as the company is working toward a long-term plan to stabilize selenium levels by 2023 and reduce levels after 2030.

"I think for a lot of us who participated in the process to create the plan, it feels like a wasted effort because the province didn't set any limits that are protective of fish and aquatic life."

The Elk Valley is a prized spot for fly-fishers, who refer to these unique trout — which have dark freckles, orange gashes along the throat and small teeth lining the mouth — as "cutties."

Westslope cutthroat trout are only found in a small portion of their original habitat and are thought to be one of the first species to populate B.C. after the last ice age. Pacific populations are listed

First Name Last Name Email Selenium, a naturally occurring element, is commonly found in coal-rich deposits and is essential to human health in very small doses. While selenium can be toxic to humans at high levels, even small amounts can be harmful to egg-laying creatures, including fish and birds. In trout it can cause spinal and facial deformities, missing gill plates and reproductive failure.

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Westslope cutthroat trout showing spinal deformities Photo A westslope cutthroat trout with a missing gill plate, a telltale Environment Canada deformity caised by selenium poisoning This trout was caught in 2014 in Coal Creek. a tributary of the Eik River. Photo Environment Canada

Westslope cutthroat trout exhibiting deformities have been found in the Elk Valley with increasing frequency in recent years.

B.C.'s general water quality guidelines recommend selenium levels be kept to two parts billion to protect aquatic life. Yet in waters throughout the Elk Valley, selenium has been measured at levels higher than 150 parts per billion.

Sexton pointed out the province's guidelines for daily selenium levels in the Upper Fording River allowed 155 parts per billion in 2014 with an expectation they would be reduced to 71 parts per billion by 2023.

"From a scientific perspective, I've never understood how the province of B.C. has been able to set these thresholds for the entire Elk River Valley that are dangerous to fish health," Sexton said.

"I always say that when I read Teck's permit, it looks to me like the Elk and Fording Rivers are a sacrifice zone."

In response to emailed questions, David Karn, a spokesperson for the B.C. Ministry of Environment and Climate Change Strategy, said the province is aware of the recent trout monitoring results and "is concerned about the declines identified."

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

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First Name availability, predation and other factors."

"We take this issue very seriously," Stannell wrote in an email. He said the company has invested $437 million to implement the Elk Valley Water Quality Plan and estimates an additional $649 to $690 million will be invested in the region, in large part for water treatment facilities, over the next five years.

In 2014, Teck introduced the $600-million Line Creek water treatment plant, which caused an alidaLUALULIL Lai six months after coming online. In 2017, the plant was taken offline after Teck discovered the treatment process was releasing a more bioavailable form of selenium into the environment, meaning it was taken up more readily by biotic life.

Since the plant was recommissioned in 2018, Teck has seen "reductions in selenium concentrations downstream of the operating Line Creek treatment facility," said Stannell, adding that two more water treatment plants are being built.

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Teck's five metallurgical coal mines are all upstream of the transboundary Koocarusa Reservoir. Map: Carol Linnitt / The Narwhal

More manes planned for the Elk Valley

Lars Sander-Green, an analyst with the local conservation group Wildsight, said the population collapse should lead to a change in the way coal mining is done in the Elk Valley. But, he said, that's far from the case.

"What's really crazy is even with this massive loss of fish, we still have Teck pushing hard on new mining expansion that would push farther into this river," Sander-Green said.

Recently Teck began the early consultation process for a major expansion of its Fording River nnorai-inne 1-1-to larnaci- nf nnynnarnr'e min inn nnarai-inn c in 1-1-1. 1211, I Tallan Tina a awn an °inn

0 First Name Last Name Email "What's happening with trout suggests things need to change in a big way if we're going to have fish in that area," he said. "It creates a lot of concerns about what is going to happen downstream in the long term."

Concerns across the border have been mounting for several years as the Elk Valley watershed drains into the Koocanusa reservoir, which extends into Montana. Selenium levels are rising in that reservoir.

"This wildlife and these landscapes don't know political boundaries," Sexton said.

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Teck coal mine in B C's Elk Valley Photo Jayce Hawkins/ The Narwhal

"I know these things get polarized across international boundaries, but I have a lot in common with people in the Elk Valley and I see it as a shared watershed. I think the U.S. gets pitted against Canada, or Montana against B.C., but I think we should all be being good stewards of our rivers together."

She added it has been "very complicated and challenging" for US. agencies and communities to be collectively outside the decision-making process in B.C., which has permitted increasing mining activity and allowed selenium pollution to grow in the Elk Valley through the decades.

"It creates this complicated environmental challenge for anyone who is a stakeholder in the watershed," Sexton said, adding there is a frustrating lack of transparency from both B.C. and Teck when it comes to monitoring and sharing raw data.

Canada has no specific, legally binding regulations on the pollution that emanates from coal mines. While such effluent regulations exist for metal mines, specific rules for coal mines have been stuck in limbo for years.

The most recent ions proposes two sets of rules, one for all coal mines and another tailored to Elk Valley operations.

The rules proposed for Teck's mines are weaker as a result of years of lobbying, Sander-Green said.

When asked about those lobbying efforts, Teck's Stannell referred The Narwhal to a 2018

First Name Last Name Email "B.C. has shown again and again they are willing to sacrifice our clean water and fish for coal mining revenue. We've seen that for decades now."

The province first established a task force to address selenium in the late 1990s.

"Since then problems have been getting worse and worse. A lot of talk but no action," Sander-Green said.

He said Wildsight is asking for a moratorium on new mining in the Elk Valley.

"We're in a big hole and we have to stop digging."

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Banner Photo' A westslope cutthroat trout. Teck Resources recently reported a dramatic decline of westslope cutthroat trout in rivers and creeks near its Elk Valley coal mining operations. Photo: Shutterstock

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