British Columbia Chapter To: Mining Operations (Southwest Region)
Total Page：16
File Type：pdf, Size：1020Kb
British Columbia Chapter 410-698 Seymour Street Vancouver, BC V6B 3K6 Coast Salish Territory Ph: (604) 685-7445 Fax: (604) 629-8532 [email protected] www.cpawsbc.org To: Mining Operations (Southwest Region) [email protected] CC: Premier John Horgan Hon. Michelle Mungall, Minister of Energy, Mines and Petroleum Resources Hon. Doug Donaldson, Minister of Forests, Lands, Natural Resource Operations and Rural Development Hon. George Heyman, Minister of Environment and Climate Change Strategy Subject: Permit for Mineral Exploration of Giant Copper 0700195 Mine Number: 0700195 Property: Giant Copper On behalf of the BC Chapter of the Canadian Parks and Wilderness Society and our 20,000 members, I am writing to register our opposition to the application from Imperial Metals to conduct exploratory mining in the Skagit Valley/Manning Park “Donut Hole” (Giant Copper 0700195). For the reasons outlined below, we urge the Ministry of Energy, Mines & Petroleum Resources and the Government of B.C. to deny the company’s application for a Multi-Year Area Based permit to conduct mineral exploration. 1. Lack of consultation with local First Nations The company has not completed their duty to consult or obtain free, prior and informed consent from the S’o lh Te me xw (Sto :lō) Nation, Syilx tmixʷ (Okanagan) Nation Alliance and Nłeʔkepmx Tmíxʷ (Nlaka’pamux) Nation Tribal Council. Imperial Metals’ application states that they have not “shared information or engaged with First Nations in the area of the proposed activity.” This must be immediately addressed before further consideration of the application. Given the BC government’s commitment to implementing the UN Declaration on the Rights of Indigenous Peoples, it is our expectation that the Ministry of Energy, Mines & Petroleum Resources will require this for any project application process. 2. Existing opposition from BC First Nations and Washington Treaty Tribes Leaders of the Washington Treaty Tribes and the Grand Chief and president of the Union of British Columbia Indian Chiefs Stewart Phillip have voiced their joint opposition to the project and permit in a recent, open letter. In this letter, they state, “[a]s Coast Salish People, we cannot allow any mining operations in the Skagit River headwaters because we must restore our salmon and preserve the rights of all those for whom salmon are a cultural lifeblood.” This watershed has been stewarded since time immemorial by the Coast Salish Peoples, who continue to speak up for the salmon species found here and the orcas which depend on the Chinook runs of the Skagit River. The Upper Skagit Indian Tribe, Union of BC Indian Chiefs, and Swinomish Indian Tribal Community have urged B.C. Premier Horgan to deny the permit for exploratory mining in the Donut Hole of the Skagit River Headwaters. 3. Over 1 million hectares of connected protected areas would be disrupted The “Donut Hole” is part of a larger, connected system of protected areas. This area is adjacent to Skagit Valley Provincial Park to the west, E.C. Manning Provincial Park to the east and Cascade Recreation Area to the north. Zooming out to the larger system, this protected area complex connects to the North Cascades National Park south of the border, flanked by several National Wilderness and Recreation Areas. This transboundary network of protection extends from Chilliwack Lake Provincial Park to Snowy Protected Area to Glacier Peak Wilderness in an adjoining network totaling over 1 million hectares of protected areas. The Manning–Skagit Valley-Cascade park complex is the northern tip of a patchwork of protected areas, which run from the southern Canadian Cascade Mountains across the border to the southern tip of the Cascades range, connecting to a network of protected areas running along the Sierra Nevada mountains into California. Disruption of this would undermine the ecological values and resiliency of this network of protected areas. 4. The North Cascades Grizzly Bear Population would be further imperiled Industrial activity in this area is in direct opposition to the province of BC’s promise to recover one of the most imperiled populations of grizzly bears in North America, the North Cascades Grizzly Bear Population Unit (GBPU). This GBPU is listed at Threatened with an estimated six remaining bears, and the only population of the southwest BC GBPU’s with an existing recovery plan. In October 2017, the Auditor General of British Columbia recommended that the Ministry of Forests, Lands and Natural Resource Operations and the Ministry of Environment identify the grizzly bear populations that are in need of recovery and outline what actions will be taken and when. These ministries promised to create a management plan, prioritizing specific populations in need of recovery. The North Cascades GBPU is already a priority for recovery on both sides of the border, an effort that would be thwarted by mining activities in the area. 5. Increased risk of forest fires The 2019 forest fire season is predicted to be well-above average severity for southern B.C., with the southern interior of BC already at high to very high fire danger as predicted by Natural Resources Canada. The Imperial Metals application details the need for water supply, settling ponds, helipads, and mother holes to carry out exploratory mining work. Although the application does not detail the source of water supply it would use, it is adjacent to Smitheram Creek, a tributary of the Skagit River, which are both likely to be affected should mining work be conducted in this area. There would be a considerable risk 2 of forest fires from machinery, heat-generating vehicles and workers put into an already high-risk fire area. In addition, the Skagit River has had low water levels in past summers, and furthering this drawdown would endanger fish survival downstream. 6. Impacts on recreational users Manning Provincial Park is one of the most beloved and highly visited parks in BC. The Skagit River is one of BC’s most important trout and char angling streams, as highlighted by the BC Fly Fishers Federation. Manning Park provides a wide range of summer and winter recreation, and includes the Manning Park Resort, which provides year-round public engagement and interpretation programs, lodging and employment. Industrial activity has already caused adverse effects to the Silver Daisy hiking trail, and additional development would put the recreational and ecological values of this area at risk. The potential noise and pollution created from mining activities, including drilling, water diversion and trenching, would further impact the recreational values of the area. 7. Impacts to species at risk, including orcas and salmon Upper Skagit has been called the crown jewel of the Salish Sea. Additional industrial activity would have watershed-wide impacts. Specifically of concern are the downstream impacts to important salmon populations. The potential impacts of metal mining in the North Cascades, including the Upper Skagit River, were studied as recently as 2017. It was concluded that aquatic ecosystems are susceptible to physical, chemical and biological changes, which can adversely affect multiple trophic levels, including macroinvertebrates and fish. The accumulation of metals in periphyton indicated these communities could be a concentrated source of toxic metals to primary consumers, such as small aquatic insects, and may pass to other aquatic organisms at higher trophic levels through dietary exposures. The poisoning of the downstream aquatic ecosystems would thwart recovery efforts carried out in the State of Washington to recover important bull trout and salmon populations in the Skagit Watershed. Jeopardizing the recovery of salmon in this watershed will further compromise food sources for the endangered Southern Resident Killer Whales. 8. Violation of the spirit and intent of the High Ross Treaty The High Ross Treaty signed between Canada and the United States settled the dispute over the flooding of part of the Upper Skagit watershed. This treaty established the Skagit- Environmental Endowment Commission (SEEC). SEEC is a bilateral body intended to conserve and protect wilderness and wildlife habitat, enhance recreation opportunities and to acquire mineral or timber rights consistent with conservation and recreational purposes. The approval of Imperial Metals’ application to conduct exploratory mining would undermine the mandate of SEEC and the spirit and intent of the High Ross Treaty. In conclusion, the approval of the Imperial Metals application to conduct exploratory mining in the Skagit Valley/Manning Park “Donut Hole” would go against the expressed opposition to the permit by local First Nations and Tribes, fracture important wildlife habitat and recreation values, and contravene BC’s legal obligations to our downstream neighbours. 3 Recommendations: 1. CPAWS-BC recommends that the BC government reject Imperial Metals’ application to conduct exploratory mining in the Skagit Valley/Manning Park “Donut Hole” (Giant Copper 0700195). 2. CPAWS-BC recommends that the BC government work with the Skagit Environmental Endowment Commission to extinguish Imperial Metals’ mineral tenure in the Skagit Valley/Manning Park Donut Hole. 3. Following that, the BC government should with First Nations who have stewarded this land since time immemorial to protect the area from future industrial threats through enduring and effective protection measures. Thank you for your time and consideration. We are available for further explanation and look forward to seeing the Skagit Valley/Manning Park Donut Hole become part of the protected areas system. Tori Ball BSc, MREM Terrestrial Campaigner Canadian Parks and Wilderness Society – BC Chapter 4 .