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Canadian Impact Assessment Registry Reference Number 80101 Grassy Mountain Coal Project Crowsnest Pass, AB

Following is my (David McIntyre) written submission to be presented at the named Hearing:

My full name, address, and phone number:

David M. McIntyre

Thank you for approving my participation in the Joint Review Panel’s Hearing.

Estimated time for my oral presentation: 45 minutes.

I ask the Joint Review Panel to not approve the proposed Grassy Mountain Coal Project.

The following explains and defines the rationale for my request that the project proposal be denied:

The proposed project is located 12 km west of my home and is seen as a threat to, not only my home life, but my entire enjoyment, appreciation, and recreational use of the area I’ve chosen to live, work, and recreate within. It’s also seen as a direct threat to already threatened wildlife and fish, a colossal—downwind and downstream—threat to the Oldman watershed and its supply of safe drinking water and irrigation water to more than 200,000 Albertans.

It is perhaps understandable, but frightening, to realize that some members of society, within a world threatened by a pandemic and financial upheaval, are quick to embrace wealthy speculators’ short-term vision of easy money and a plethora of dark unknowns in trade for world-class vistas, and quality-of-life living.

What’s surprising is society’s tendency, particularly during tough times, to embrace futuristic engineering schemes and untried technology while discounting scientific knowns and a need for honest rigor, full-equation knowledge, and full-spectrum research. As a result, some people are already launching dreams of instant wealth while blind to many other economic options that are available. They stand poised to assault the land that sustains life and its free, but increasingly rare, gift of clear, clean water.

Do these people—perhaps the are unsure of themselves—see only the fleeting highlights of a dark and dirty past? Do they stumble and, in falling, see nothing more than a foreign speculator’s cash, an outreached hand and, with it, a promise of prosperity? If society reaches up to accept this cash-laden offer, it accepts, too, its liabilities and must stand willing to throw away all other forms of economic advantage and long-range virtue.

The Oldman watershed, in addition to being the water tower for more than 200,000 Albertans, is a cathedral, a place of worship, not just for indigenous people. Its doors are open to everyone. It’s a world-class tabernacle known around the world. (A possible addition here are the dying words—they’re in one of my Statements of Concern (SOC)—of eminent Canadian geologist, George Dawson.) 2

This headwaters landscape, a priceless possession, belongs, not just to the people of Crowsnest Pass or the people of Alberta, but to all Canadians. It’s a rare and spectacular asset worth billions. It should never be squandered for someone else’s short-term gain. Alberta’s long-range wealth, health, and prosperity depend on its ability to keep intact the mountains that feed our souls, provide us with clear, clean water, and offer us a wild landscape in which to grow, a land we can share—intact!—with the world that passes at our doorstep.

The proposed project, even in its conception, brings stress and concern and detracts from my ability to enjoy, fully, my home, life, and quality-of-life living. I’m overwhelmed by the perceived need to invest in the expenditure—at my own time and expense—of hundreds of hours in an effort to articulate and present my concerns within the highly technical and demanding requirements of Joint Panel submissions. Given the problems and hurdles I’ve faced, and the colossal investments of time this has forced me to spend, it’s easy to see why my neighbors and countless additional concerned Albertans offer me verbal support and encouragement while reporting that the process, for them, is too daunting, a mountain too intimidating to attempt.

I stand here today because I’m convinced the proposed project fails to serve society, poses known and obvious health and welfare threats to the populace, needlessly degrades the environment and its life-sustaining gift of clear, clean water, and effectively kills all other economic options within a region—The Crown of the Continent—characterized by world-class beauty and open-vista intrigue.

The world is changing. Climate change issues demand that we step past the past. The Elk River’s dead and dying trout are today’s canary in Canada’s dirty, dusty coal pits. These trout, in death, speak to us in terms of assessing the worth of open-pit coal mining.

As a graduate student at the University of Washington, College of the Environment (Seattle, WA) during the mid-70s, I asked for, and received permission to embark on a route, as a broad foundation and complement to my degree, no one, to my knowledge, had ever previously undertaken. I took graduate-level field classes in a number of environmental disciplines outside my primary field of study: forest science. As a result, I, with the benefit of extensive field trips throughout the Pacific Northwest, studied botany, geology, ornithology, zoology, wildlife science. and more.

During this same time, the Smithsonian Institution contacted the dean of the College of the Environment and asked him to select a professor to lead, through the Pacific Northwest, a ten- day forest science study tour.

I was handed this golden opportunity, and used it to create an international-in-scope educational effort that, as it expanded during the following two decades, allowed me, working for the Smithsonian Institution, to guide educationally focused hiking and whitewater rafting tours—each 10 - 14 days in length—throughout much of the US West and western Canada.

I led these tours through numerous national parks including Mt. Rainier, Olympic, North Cascades, Glacier (USA), as well as Banff, Jasper, Yoho, Kootenay, and Waterton Lakes. I also led educationally-focused whitewater rafting trips down the Salmon River in Idaho, the Middle Fork of the Salmon, and the Colorado River through Grand Canyon. I did this for 20 years.

The Smithsonian study tours exposed me to a diverse clientele: medical doctors, lawyers, engineers, educators, politicians, judges, geologists and a host of other scientists from all walks of life. I learned from these people perhaps more than I was able to give them. The exchanges were often deep. All were grounded within the raw-earth, sense-of-place power that 3 emanates from national parks and equivalent reserves, places bathed in Earth’s cultural and natural riches, its quintessential capacity to frame and support life.

During my graduate studies, I had occasion to visit southern Alberta and travel through Crowsnest Pass. I, instantly, fell in love with the area’s raw beauty, its visible wildlife, its edge- of-world intrigue. I was disturbed, however, by the sight of a coal-blackened landscape and coal-blackened roadside miners who stood at highway’s edge waiting for the company bus.

Shortly afterward, I, in love with the landforms of southern Alberta, and with the province’s progressive vision, was offered an opportunity to work for the Government of Alberta’s (GoA) Department of Parks, Recreation, and Wildlife. There, I turned down offers of work in Edmonton in order to manage interpretive programming in southern Alberta, where my focus of intrigue with the land and its people allowed me to direct the delivery of educational programs at a number of parks including Cypress Hills, Dinosaur, and Writing-On-Stone. This experience, and exposure, further broadened my understanding of cultural and natural history resources, particularly in the fields of archaeology and paleontology.

As the last of Crowsnest Pass’s active coal mines closed (circa 1983), I, wishing to move to the extreme southwestern corner of the province to live within its—this is my chosen home— striking beauty, sought a newly advertised job, lesser in pay, but infinitely greater in offering me the opportunity to live on a land that, to me, was heavenly.

I applied for and was given the job of managing, for Alberta Culture, interpretive programming for a number of sites including Frank Slide, Head Smashed in Buffalo Jump, and Turner Valley. My new home: Crowsnest Pass, Alberta.

… and so it came to pass that I, in love with “the Pass”—as it’s called by locals, as if it’s the only mountain pass on Earth—came back to the Pass and its raw surroundings of natural beauty. I came back despite a plethora of lingering scars left by unreclaimed mines. I came back, too, because the Pass’s dirty affair with coal mining was history, a thing of the past. The land was no longer black with coal dust. There was beauty. You could again hang your laundry in the west wind. And the land, some of it wounded and bleeding, could begin to heal.

My wife and I met on this land. She, from a nearby ranching family, knew from her childhood that this was where she wanted to live. Our paths intersected on this arresting thrust-faulted landscape where a wind-shaped pygmy forest characterized by ancient limber pines and whitebark pines reached up to towering cliffs and a spiritual power peak known as Crowsnest Mountain. We met amid the rubble of the 1903 Frank Slide, North America’s deadliest rock avalanche, and one of Alberta’s worst life-claiming disasters. Only the across-the-valley 1914 Hillcrest Mine Explosion has claimed a greater toll.

My job with the GoA enabled me to work for more than a decade with scientists, geophysicists, and engineers engaged in deformation monitoring of Turtle Mountain, producer of the 1903 Frank Slide.

Turtle Mountain, within its current state of structural collapse, is forecast to produce a future rockslide capable of claiming human life, crossing the Crowsnest River valley, and inundating the Canadian Pacific Railway line and Highway 3. When will this occur? No one knows.

Following my GoA employment and the 100th anniversary of the Frank Slide, then Premier Ralph Klein, at the anniversary ceremony (2003), announced the GoA’s commitment to renew, upgrade, and support the Turtle Mountain monitoring program. I was asked to join this new deformation monitoring team. 4

It’s my long-range exposure to the ongoing threat imposed by Turtle Mountain that causes me to express concern today for the potential of close-proximity mine blasts from Grassy Mountain to generate seismicity that could trigger and/or otherwise accelerate and exacerbate the potential for Turtle Mountain’s well-known and already unstable structure to fail, and do this in a potentially life threatening, catastrophic way. (A major rock avalanche cascaded from the northern flanks of “nearby” Chief Mountain (MT) on July 2, 1992, burying hundreds of acres under a virtual sea of rock. The cause of the rock avalanche: a small earthquake. See, too, my Jan. 14, 2020 op-ed “Fallout from Turtle Mountain” as it appeared in the Lethbridge Herald.)

I believe it’s inherently dangerous to engage in any “experiment” that has the added risk of exacerbating the known risk Turtle Mountain poses to the lives of those who pass beneath it. The mountain’s existing display of its potential to transform the valley and claim human life is, I would think, more than enough to promote profound caution, extreme restraint. There’s no need to add the impact of close-proximity mine blasts to an already crumbling equation.

My wife and I have likely spent more time hiking throughout the greater Crowsnest Pass than any living couple. We’ve each walked, literally, tens of thousands of kilometers (an estimated 50,000 kilometers) on this landscape during the past three decades alone, i.e., the equivalent, and more, of walking around the Earth at the equator.

During the past few decades, however, we’ve reluctantly retreated from many of the Crowsnest Pass haunts that we initially found so alluring. Why? Wanton destruction of the land by users and abusers. We, in love with the land, found it difficult to bear the burden of seeing the abuse.

One of the things that I—and my wife—brought to the Oldman’s headwaters landscape was an innate curiosity to discover our own chosen brand of hidden treasure. We, for example, high on the cliffs of Sentry Mountain, discovered—and photographed the entry to—The Booming Ice Chasm 13 years before the same cave was “discovered” and named by cavers who came after us. We have also found prehistoric pictographs within a cave on Bluff Mountain—it’s immediately south of Grassy Mountain—and documented rare orchids—currently being excavated by off-road abuses—on the flanks of Tecumseh Mountain. There’s more.

Shortly after moving to Crowsnest Pass, I reported another unexpected discovery: The headwaters of the Crowsnest River was home to Alberta’s rarest, most diverse, forest community, a previously undocumented, unreported range of tree species found nowhere else in the province. What did this do to alter logging practices? Nothing. When I was interviewed by the Canadian Broadcasting Company in 2008 in response to my concern that this one-of-a- kind forest was being logged on the flanks of Crowsnest Mountain, reporter Jennifer Keene, following the formal interview, asked me if there was anything else I was concerned about. I responded by telling her I thought there might be native pure-strain cutthroat trout in the upper reaches of Allison Creek (flowing below us). I, later, brought this thought to provincial fisheries biologists, and was laughed at, … but they agreed to DNA test trout above a waterfall I described, one they weren’t aware of. The outcome: Pure-strain westslope cutthroats were present. The results prompted me to ask that Girardi Creek (on the opposite side of the Crowsnest River valley) be similarly sampled. It, too, proved to be home to threatened, pure- strain cutthroats.

But here are the important aspects of these discoveries: Was Alberta’s rarest forest community saved? Have rare orchids been saved? Have the identified and threatened populations of native trout been saved? Has the GoA done anything that’s altered a picture of ongoing destruction of precious, irreplaceable natural resources? Within the bleak answer, it’s my thought that Allison’s cutthroats have been killed during the past decade due to ongoing logging operations and rampant off-road abuses within the Allison Creek watershed. 5

It’s also my firm belief, as a forest scientist, that the price we’ve paid to manage the high, dry, matchstick forest of southwestern Alberta has already cost society far more than the forest’s hypothetical projected worth, as measured in merchantable timber, assuming this slow growing “crop” can be harvested before invading insects or wildfires kill it. Imagine the risks involved in attempting to grow a crop that doesn’t mature for 100 years. Imagine this as climate change adds drought and heat to the equation. Imagine this as hungry forest pathogens propagate in wild response to a weak, old forest’s susceptibility to attack. Imagine the ever-accelerating risk of wildfire. Look toward California and Oregon for answers.

What does any of the preceding have to do with open-pit coal mining? Everything! Whatever GoA land-use and resource extraction rules and regulations exist, they appear to have so little impact in preserving Alberta’s headwaters landscape and/or protecting rare and threatened species that they appear meaningless. Also, and of perhaps even greater importance, the reported values of wood production and in-the-ground resources are often at extreme variance with the real worth of these products, once extracted. And there’s this: The true cost of reclamation or restoration is seldom—if ever!—factored in with meaningful integrity by those who seek profit from investment opportunity.

What, given the preceding, happens when the cold, hard facts are considered within a picture of an already-over-committed, ever-shrinking headwaters watershed’s ability to function? What happens as climate change continues to add its choking grip to a growing water crisis? Do we ignore climate change and its impacts on our lives, the lives of our descendants, and the Earth as we know it? It’s common knowledge that the Oldman watershed is overcommitted. It’s common knowledge that climatologists project, over decades, ever-declining flows in the Oldman River.

The current (Sept. 21, 2020) picture: Alberta Environment issued (in July) a Water Shortage Advisory for the Castle, Crowsnest, and Upper Oldman rivers.

A parallel problem: Projects that receive government approval are often in conflict with the common good of society as a whole, and very likely to be nothing more than stock market scams. They’re very prone to be fly-by-night, ill-advised schemes that add wealth to the rich, degrade the life-sustaining virtue of the land, and further impoverish the poor. A quick look at the current state of North America’s coal mining towns paints a picture of impoverished living and poor health.

I’ve invested decades in uphill conservation efforts in southwestern Alberta. I’ve worked within the system to have threatened species receive the protection they deserve. I’ve worked to create awareness of and protection for rare, one-of-a-kind landscapes. My efforts, considerable, have failed on every front. All I and others with similar aspirations appear to have generated: additional government paperwork and overtime pay for government employees who, in the process, have proved inept and/or incapable of actually solving or rectifying any—is there a single success story?—of numerous glaring concerns and issues that were brought to their attention.

In each and every case I’ve been involved in, rampant and degrading land-abuse practices have accelerated after the issue was brought to the GoA’s attention. Each and every issue I’ve brought to the GoA’s attention has worsened after I acquired GoA “support.” Never has the GoA shown itself capable of turning the tide when I placed a concern or call-for-action on its boardroom table. 6

The Oldman’s headwaters, today, are at a critical, catastrophic crossroads. This now- endangered headwaters landscape can tolerate no further abuse without failing to support native trout—they’re already in grave peril—and other species as well as its many thousands of water-dependent downstream users.

Based on decades of observation and attempts to work within the GoA’s ability to address land-use issues, I do not believe there exists, within the government, the will, the capacity, or the credibility required to address the land and watershed degradation issues that, out of control, were running rampant throughout the Oldman’s headwaters before it opened (June 1, 2020) the mud-gates to rampant coal exploration throughout Alberta’s Eastern Slopes. It appears clear to me that prompt and honest intervention is required if Alberta’s headwaters— our watershed!—can be saved.

I live on the outer edge of Crowsnest Pass, a community that is still defined, to a large degree, by its brawling, combative past. It’s a fractious community characterized by rough edges, tough characters, and an active bully culture. It’s a community in which most people are afraid to speak if their views tip toward any form of restrictive land use or activity. “Mountain Freedom” is the battle cry, the ability to throw the rule book away and do anything a hard-ridin’, heavy-drinkin’, dirt-spewin’, landscape-degradin’ maverick heart desires.

It’s here on this landscape that I’ve expressed and exposed my protect-the-land views and, daily, paid the price. I’ve had my vehicle’s tires slashed, my car windshield smashed by what was almost certainly the heavy swing of a hand-wielded axe, and I’ve weathered the experience of discovering that another individual’s (John MacGarva) letter to the editor, a letter presumed libelous and laden with false and misleading information about me, was printed in a local newspaper.

Despite the described hurdles and the feeling that, wherever I go, I’m being watched, I continue to advocate for landscape integrity and resource protection. What I no longer seek, however, is GoA assistance in achieving these goals. The province, in my opinion, has repeatedly proved itself inept and/or incapable of addressing land-use issues. A more committed, functional, and focused entity is required.

The last thing Alberta’s headwaters landscape needs and is capable of tolerating is a land- degrading, watershed-destroying force in addition to those, pre-June 1, 2020, that the GoA, repeatedly, and for decades, has proved itself incapable of managing in a sound and credible way.

I’m amazed that the proposed Grassy Mountain Coal project is, today, deemed to possess sufficient worth to proceed to a public hearing. I’m amazed that human health issues—doctors know these in spades—and concerns for sustainable water—ask any credible hydrologist or climatologist—haven’t derailed the project and the GoA’s interest in it. I’m amazed, too, that the project’s potential to generate colossal down-wind and downstream detrimental impacts on agriculture, recreation, tourism, the economy and quality-of-life living haven’t already turned wild speculation into broad-based cries for help from the public. The answer, I suggest, lies in the fact that most Albertans have no idea of what’s going on “down here” in the land down- under, a land off the public radar screen. Media focus and public focus are on the pandemic and the economy.

The people of “the Pass” have weathered hardship, tough times, and an unthinkable litany of disasters. Perhaps nothing speaks so succinctly and with such power as the voice of those who have lived through Crowsnest Pass’s black times, people who can look at their roots and see the meager wins and the colossal losses witnessed during their journey through life. These 7 people, and all Canadians, stand at the crossroads that bring us to this point in time. There are those who look favorably upon the dirty vision of returning to the vagaries of their coal-mining past. Others wish to turn their backs on the black vision of living in the back seat of someone’s else’s money-waving speculative ploy. I suggest that futuristic, long-range thinkers are focused on the clean air and spectacular mountains at their doorstep. They, wising to write their own future, are inspired, willing and able to step forward into a world forged on the backbone of the Rocky Mountains, a world that embraces and draws its strength and economic viability from its long-range thinking, its world-class surroundings … a world that lies at the hallowed, sacred foot of Crowsnest Mountain.

The greater Crowsnest Pass and the work-and-play lives of the people passing through embody a paradoxical puzzle, a dichotomy that places those who most love of the land in conflict with those who seek to exploit it and destroy it for perceived short-term gain. For those of us who actively chose—and choose—to live here, we love our mountainous home for its raw, wild beauty. We immerse ourselves so inextricably within this vision we began to feel we own the land, that it’s ours. In truth, however, it’s the mountains that own us. We belong to them and look to them for strength and guidance. The mountains, our hope and salvation, are not here to be sacrificed.

Questions: Will Albertans destroy their headwaters heritage and cripple their future for someone else’s short-term gain? Do Albertans and Canadians stand in support of adding to Canada’s needless contribution to global warming? These are questions we might ask of people living in the wildfire-ravaged lands of California and Oregon … or maybe we simply need to ask the residents of “nearby” Fort MacMurray.

Two things the Grassy Mountain Review Panel must initiate, in my opinion, in the interest of full public awareness and disclosure:

• A detailed, investigative report that, clearly and definitively, conveys what happened to Gold Creek’s “missing” (and presumed dead) trout in the wake of an apparent July 30, 2015 collapse of waste coal from the eastern flanks of Grassy Mountain. Who was responsible for this event, what caused it, and what, exactly, did it do to the population of native cutthroats in Gold Creek? (See my Dec. 8, 2017 Statement of Concern for added detail.) • A similar document, complete with the results of independent, lab-tested water samples, that reveals, precisely, what caused Blairmore Creek to, on April 13, 2017, appear orange and laden with acid runoff. What do independent toxicologists report via the analyzed water samples? Who was responsible for this event, what created this situation, and what were the threats to aquatic life and public drinking water? (See my Dec. 8, 2017 Statement of Concern for added detail.) 8

My already-submitted Statements of Concern (SOC) are attached to this document. I’ve done this because, even after spending untold hours in an attempt to find and record the defining IAAC and AER reference numbers for these documents, at least one of these SOCs—it’s dated Dec. 8, 2017—appears to be missing. Also, I was promised some years ago that the IAAC and AER would integrate their files such that a search for, say, all SOCs presented in response to the Grassy Mountain proposal, would reveal all SOCs, not a fractured, incomplete accounting. Seemingly, this update and level of fluid, transparent revelation has not yet been realized. i’m providing, here, added climatological data, and doing this primarily due to its importance in attempting to determine how wind can impact and exacerbate a plethora of health, wildfire, and other dust-distribution concerns:

The hurricane-force winds that tear along the front ranges of the Alberta Rockies are legendary. Known as the Chinook, the Snoweater, and certainly by more colorful names, these winds are sometimes a blessing. They can also be a lethal curse. It’s likely that AltaLink and Fortis Alberta know the associated costs as well as anyone. Each has likely experienced millions in unexpected line repairs due to savage, equipment-destroying winds in, and through, the Oldman headwaters landscape.

TC Energy, formerly TransCanada Pipeline, also knows well the vagaries of the region’s winds. The company, for approximately three decades, has been trying to reclaim and revegetate a portion of its twin line approximately 10 km north of my home, and roughly the same distance from Grassy Mountain. TC Energy has invested heavily in this since, I believe, 1991, and yet its efforts, ongoing, appear to have failed. Within recent years, the company, a contractor, or other available workforce has, as a part of the ongoing reclamation effort, excavated dozens of ancient, endangered, living limber pines … and then transported these trees, dead, to the pipeline route—I can provide a picture—where they, along with rebar, are being used in an attempt to stabilize the fill above the pipeline and propagate vegetative growth. There are probably far more costly failed reclamation efforts on this Oldman headwaters landscape but there may be no finer land-defining example of how a rare and endangered species has been killed for no reason other than the envisioned use of its stark, lifeless remains as windbreaks and soil anchors. (The GoA, however, tried for years to eradicate ancient forests of whitebark pines on this same landscape—the trees were bulldozed and burned—before turning its back on this practice and, within the last decade or so, working to document the presence of whitebark pines on the land, acknowledge the trees as an endangered species, and work to protect them … at least on paper.)

Supplemental weather data

I’m attaching here, as a part of my submission, a month-by-month summary of weather data for 2019 as recorded (via Davis Instruments Vantage Pro2) by a neighbor (Rolf Brinkmann) and sent (by him) to Environment Canada. The latter is the recipient of more than 10 years of weather data (2010 - 2020) from Mr. Brinkmann. The following data from 2019 deliver a picture similar to the preceding years, although Mr. Brinkmann reports that his recorded data reflect a noticeable trend toward hotter drier conditions:

ANNUAL CLIMATOLOGICAL SUMMARY

NAME: Sation 1 CITY: STATE: ELEV: 1463 m LAT: 49∞ 39' 02" N LONG: 114∞ 17' 17" W

TEMPERATURE (∞C), HEAT BASE 18.3, COOL BASE 18.3 DEP. HEAT COOL 9

MEAN MEAN FROM DEG DEG MAX MAX MIN MIN YR MO MAX MIN MEAN NORM DAYS DAYS HI DATE LOW DATE >=32 <=0 <=0 <=-18 ------19 1 2.8 -5.3 -1.0 0.0 598 0 10.9 14 -15.5 18 0 10 24 0 19 2 -12.0 -22.0 -16.8 0.0 984 0 5.6 1 -31.2 10 0 26 28 21 19 3 2.9 -8.0 -2.7 0.0 651 0 16.7 20 -31.3 2 0 9 28 7 19 4 8.2 0.0 4.0 0.0 430 0 14.4 22 -8.6 29 0 0 15 0 19 5 12.4 3.0 7.6 0.0 336 3 23.4 29 -5.7 1 0 0 6 0 19 6 17.8 7.0 12.8 0.0 176 9 24.9 13 0.4 20 0 0 0 0 19 7 19.9 9.1 14.8 0.0 133 24 28.4 23 3.6 8 0 0 0 0 19 8 20.9 8.9 15.3 0.0 105 19 28.2 8 2.9 17 0 0 0 0 19 9 13.6 5.6 9.8 0.0 260 4 24.2 3 -9.5 30 0 3 5 0 19 10 5.8 -2.7 1.7 0.0 516 0 13.8 16 -19.4 29 0 4 18 1 19 11 2.6 -6.1 -1.5 0.0 594 0 11.3 8 -22.1 29 0 8 21 5 19 12 2.0 -4.5 -1.3 0.0 607 0 6.2 6 -16.2 8 0 9 27 0 ------8.1 -1.2 3.6 0.0 5392 58 28.4 JUL -31.3 MAR 0 69 172 34

PRECIPITATION (mm)

DEP. MAX DAYS OF RAIN FROM OBS. OVER YR MO TOTAL NORM DAY DATE .2 2 20 ------19 1 3.8 0.0 1.4 2 7 0 0 19 2 6.8 0.0 2.2 2 6 1 0 19 3 9.2 0.0 3.8 28 8 2 0 19 4 18.4 0.0 4.6 19 14 5 0 19 5 66.8 0.0 12.8 16 18 10 0 19 6 50.4 0.0 10.4 14 15 10 0 19 7 59.4 0.0 22.6 20 10 6 1 19 8 47.5 0.0 15.5 16 9 6 0 19 9 55.9 0.0 13.2 19 15 8 0 19 10 5.4 0.0 1.2 8 11 0 0 19 11 5.6 0.0 1.6 20 10 0 0 19 12 8.8 0.0 3.6 20 10 2 0 ------338.0 0.0 22.6 JUL 133 50 1

WIND SPEED (km/hr) DOM YR MO AVG. HI DATE DIR ------19 1 28.5 144.8 2 W 19 2 10.1 99.8 22 S 19 3 13.9 119.1 11 W 19 4 17.8 104.6 19 SW 19 5 11.3 91.7 3 N 19 6 14.6 74.0 6 SW 19 7 12.5 91.7 24 WSW 19 8 10.6 88.5 18 WSW 19 9 14.5 115.9 23 WSW 19 10 25.2 114.3 7 W 10

19 11 24.7 128.7 17 W 19 12 30.2 127.1 2 WSW ------17.9 144.8 JAN WSW

I provide the preceding to provide a dynamic, downwind picture of the potential for dust and coal fines from Grassy Mountain to travel what’s likely tens of kilometers downwind from their point of origin, to, on snow, accelerate spring melting, streamflows, and degrade the health and quality-of-life living for the region’s inhabitants. How, too, might wind-born dust and coal fines impact the already threatened population of pure-strain westslope cutthroat in Rock Creek, a stream with its headwaters a virtual stone’s throw from Riversdale’s planned epicenter of activity? Todd Creek, with a similar population of threatened native trout, is similarly positioned. So, too, is Daisy Creek. 11

I wrote the following—I believe it’s important, and telling—on October 23, 2016 after attending, in Fernie, BC, the 7th annual Crown of the Continent Roundtable conference:

The Crown of the Continent, the Crowsnest Pass’ internationally embraced backyard

by David McIntyre

I attended the 7th annual Crown of the Continent conference this past week (Oct. 13th and 14th) in Fernie, B.C. The “Crown” as it’s known to its many partners, is a remarkable, internationally known and marketed landscape. It’s gorgeous, ecologically intact, rich in history and natural resources. It’s home to thriving communities. Glacier National Park (MT) and Waterton Lakes National Park (AB) define the “Crown’s” captivating core.

There are problems. The 18-million acre Crown of the Continent landscape is threatened by climate change, loss of traditional knowledge, growth and development.

The conference was designed to address these product-degrading threats by providing a forum for collaboration and networking among Tribes/First Nations, land managing agencies, local governments, private land partnerships, academia, conservation groups, businesses, and industry.

The job: colossal.

The commitment from participants: titanic.

The theme of this year’s conference: One Backyard: Celebrating a Shared Landscape.

The Fernie meeting brought the Crown’s many partners together and provided roundtable discussions. The shared goal: enhance the culture, community and conservation values across the USA-Canada border, and between the Crown’s two Canadian provinces (AB and BC). 12

Among the symposium's many presenters, three mayors from the transboundary landscape were invited to discuss their challenges and successes. The three: Mayor Mary Giuliano, Fernie; Mayor John Muhlfeld, Whitefish; and Mayor Blair Painter, Crowsnest Pass. (Previous mayors from Crowsnest Pass have participated in preceding Crown workshops.)

Background: Fernie, Whitefish and Crowsnest Pass share similar populations (4,500 - 7,500), but vary in footprint, with Crowsnest Pass having a much larger land base than the other two. It’s therefore interesting —absurd might be a better word—that Crowsnest Pass couldn’t be found— it didn’t exist—on the conference maps of the region. The community’s “black hole existence” created a massive identity problem. It’s a problem that, I’ve noticed, also manifests itself on most Alberta-produced maps. Where is Crowsnest Pass, AB, and how does the community, despite its large footprint and population, fail to appear on maps that name and draw attention to the much smaller towns surrounding it?

Mayor Painter addressed Crowsnest Pass' challenges and hopes for a better tomorrow. He spoke of the community’s lack of an industrial tax base, and said he was looking forward to Riversdale’s startup (an outcome that, it was noted, is not assured—it remains dependent on yet-to-be- determined reviews and assessments).

Mayor Painter stated that a mine within the community would have no impact on tourism, and described himself as pro-coal, and the community as pro-coal.

Countering Painter’s position, Fernie councillor Phil Iddon, speaking on behalf of Fernie, and contemplating the vision of a mine within the City of Fernie, reported that he didn’t want industry in “our bubble,” a reference to Fernie. Iddon added, “I don’t think people would tolerate industrial development in our community.”

John Muhlfeld, Whitefish mayor, reported that his community has very little industrial land. He articulated the need to focus on protecting the quality of life for Whitefish residents. He said he wanted to “quench people’s thirst for authenticity and quality of life.” Muhlfeld added that Whitefish is working to reduce its night-light profile in an effort to achieve a “dark sky” vision, a 13 concept that’s being marketed successfully in nearby Glacier National Park. There, the park’s success in drawing visitors has been so great that the water supply and the park’s infrastructure have been stretched to their absolute limits.

Glacier National Park Superintendent Jeff Mow, addressing the problem— more than two million visitors annually—reported the need to replicate and support the park experience outside the park to decrease the pressure within. In other words, the communities bordering the park were being looked upon to shoulder Glacier’s overwhelming appeal, and benefit from the resulting economic potential.

Mayor Painter, when asked his thoughts about the “new park in the Castle,” appeared uncomfortable with the question, and indicated he was waiting to see what the Gov. of Alberta intended to do with the park before offering comment. 14

My (David McIntyre) Nine Statements of Concern (presented in chronological order)

I’m attaching here, my nine Statements of Concern, at least one of which( dated Dec. 8, 2017) does not appear to have been entered on the IAAC’s or the AER’s registry. (I’ve spent untold hours in multi-day efforts to find and thus present (as requested) my own SOCs as identified within the IAAC/AER datasets that, if they’ve designed to thwart participation in a public review process, are, in my opinion, deserving of awards in defining their success.): 15

From: David McIntyre

Sent: Jun 13, 2015

To: Grassy Mountain (CEAA/ACEE)

Gov. of Canada Reference Number: 28

Follow Up Flag: Flag Status:

From: Sent: To: Subject:

Follow Up Flag: Flag Status: The following aspects of the environment may be affected by the proposed project: 1. Headwaters health and integrity, particularly as it relates to threats of sedimentation, selenium, nitrates and erosion

2. Water, both qualitatively and quantitatively, for society and for the ecological integrity of native species

3. Threatened native trout species, particularly pure-strain westslope cutthroat trout in Blairmore and Gold creeks

4. The “mountain removal” aspect of the proposal is one thing, its cumulative impact on the land is another 16

5. The network of linear disturbances on the land already exceeds thresholds considered tolerable for some species

6. Aesthetic values within an internationally revered and marketed Crown of the Continent landscape

7. Air quality, perhaps particularly as it relates to an area that experiences regular hurricane-force winds

8. Noise pollution, its impact on humans and wildlife

9. Health and safety of the populace and indigenous flora/fauna

10. Grizzly bears and native trout should be at the top of the special- species-of-concern list

My wife and I live on the eastern flanks of the Livingstone Range, approximately 12 km east of Grassy Mountain. The Livingstone Range blocks our view of Grassy Mountain. It’s out of sight, not out of mind. Particularly disturbing is the unanticipated discovery that we, at our home, are subjected to the droning industrial noise that’s been associated with the proponent’s recent exploration work on Grassy Mountain. We never anticipated this outcome. The community of Crowsnest Pass, set amid some of Canada’s most spectacular scenery and surrounded by stunning mountain ranges, has endured the ravages of industry’s failure to save and safeguard the headwaters landscape. Scars from the unreclaimed abuses of open pit mining are visible from space on Tent Mountain and Grassy Mountain, 17 and other mines in the headwaters of the Crowsnest River valley reveal similar degradation, i.e., there is, perhaps, no “finer” example of the government’s appalling and continual failure to monitor and control industry than the land surrounding the proposed project, no more compelling reason to do far more to protect the environment than has been done before. Crowsnest Pass is the lowest trans-Rocky Mountain pass between New Mexico and Jasper National Park. This low elevation pass, and the adjacent low passes (Tent Mountain Pass and Deadman Pass) form an incredible through-the-mountain-range conduit for species dispersal. This pass is likely responsible for the presence of bull trout and westslope cutthroat trout in Alberta, and for west-to-east plant colonization. The forests in the headwaters of the Crowsnest River are Alberta’s rarest, most diverse, most threatened, and home to tree species that are found nowhere else in the province. The preceding forms a footnote of sorts, and says this: Expect to find the unusual, the unexpected and the unlikely in the landscape surrounding Grassy Mountain.

David McIntyre

June 13, 2015 11:21 AM Grassy Mountain (CEAA/ACEE)

Grassy Mountain Project—Crowsnest Pass, AB

Follow up Flagged

1 It’s likely that society knows more about what’s under the ground in the greater Crowsnest Pass than it does about what’s living on the surface. Alberta’s capacity to be “open for business” needs to be reined-in to align with the environment’s capacity to make business possible without degrading life for the people of Alberta, and without constantly 18 devaluing the environment and reducing its capacity to maintain its intrinsic—naturally given—ecological health. The bottom line: Alberta’s headwaters landscapes must be treated as ecological gold mines. And water on Alberta’s Eastern Slopes is gold. It’s priceless, it’s rare and it’s increasingly in peril. We can’t allow it to be stolen or squandered. Alberta and Canada need to demonstrate, to Albertans, the Canadian populace, and to the world, that the elected government is capable of governing Canada, and saving Canada for the people of Canada. Sincerely, David McIntyre 19

January 15, 2016

Authorizations Review & Coordination Team Alberta Energy Regulator Suite 1000, 250 – 5 Street SW Calgary, Alberta T2P 0R4

Benga Mining Limited PO Box 660 12331 – 20 Avenue Blairmore, Alberta T0K 0E0 Attention: Cal Clark

Re: Application-1844520#sthash.ASUXxqom.dpuf

STATEMENT OF CONCERN AND OBJECTION REGARDING: Application No. 1844520 and 1844522 Riversdale Resources / Benga Mining Ltd. - Grassy Mountain Coal Project

Personal Information:

Statement filed by: David M. McIntyre Statement of Concern Filed : January 15, 2016 Contact Information:

Legal l , W 5th (approximately 12 km east of Grassy Mountain)

I am directly affected by the proposed project: My wife and I live east (downwind) of the project, and we have already been subjected to industrial noise from its developmental stage. We are further concerned with air quality, dust from coal fines and other airborne material.

Gold Creek has been a recreational and spiritual sanctuary for me for more than three decades, and I have introduced international anglers to it, people who have repeatedly returned to the creek’s cascading, trout-rich pools. Blairmore Creek, too, has been a sanctuary and recreational retreat for a similar period of time, and among my favorite memories are nights in which I cross-country skied from its headwaters to Highway 3. How might the mining of Grassy Mountain impact threatened populations of pure-strain westslope cutthroat trout in Gold and Blairmore creeks, and, potentially, the Crowsnest River? Have Gold Creek’s cutthroats already fallen victim during Benga’s developmental stages of work? 20

I’ve participated in annual raptor counts from Piitaistakis (Place of the Eagles), on the nearby crest of the Livingstone Range, home to the world’s greatest concentration of migrating golden eagles—more than 1,000 of these majestic raptors have been counted at this site in a single day. Thousands of additional raptors (and other birds) traverse this migration route twice each year, and the observation site on the Livingstone Range continues to be promoted (National Geographic) internationally. How might the mining of coal on Grassy Mountain impact migrating birds and/or an internationally marketed geotourism product? The envisioned picture: not pretty.

Grassy Mountain lies within the Crown of the Continent, a large, internationally marketed area that, due to its aesthetic appeal, ecological health and stunning worth to geotourism, is acclaimed around the world. Alberta, BC and Montana are all Crown of the Continent partners/supporters, actively working to ensure the region retains its cutting edge appeal and marketability. Coal mines are not part of this product and, without doubt, scar and degrade geotourism values. Similarly, an active coal mine at the doorstep and gateway to the newly designated Castle Park would devalue the park at its point of entry.

Interestingly, and alarmingly, Benga’s coal lease holdings, and other coal lease properties, extend far from Grassy Mountain and threaten wild-land vistas throughout the greater Crowsnest Pass, a community with one of the world’s most striking mountain backdrops. Thus, there is the potential to degrade tourism throughout the region while lowering property values and compromising residents’ quality of life … and presumably their health.

Grassy Mountain is also in close proximity to Robertson Peak (also on the LIvingstone Range), where prehistoric vision quest sites look out at Chief Mountain (MT) and Crowsnest Mountain, the two featured spiritual power peaks. The view of Crowsnest Mountain, from this sacred site, looks directly over—and at—the summit of Grassy Mountain.

“Prayer flags” continue to appear along the crest of the Livingstone Range, thus suggesting (strongly) continued use of the area by First Nations people, people who, more than 5,000 years ago, began mining chert from the crest of the Livingstone Range. How might contemporary coal mining impact the lives and spirituality of First Nations people, and others with the same values? (The Crowsnest River valley is home to the greatest concentration of prehistoric archaeological sites in the Canadian Rockies, and it’s certain that many sites have not yet been mapped.)

I’m a forest scientist with an acute interest and passion for science-based knowledge on many fronts. I have, for years, been involved in the mapping and protection of limber and whitebark pine on the Alberta landscape. These species, recently classified “endangered” by the Gov. of AB, are of special interest to many people from all walks of life. Some of these old pines may be more than 1,000 years of age. Both of these species of five-needle pines occur in the Grassy Mountain area, and it’s likely that 21 western white pine, Ponderosa pine and western redcedar—all three species are even rarer in Alberta—are present as well.

In addition to my concern for the welfare of pure-strain westslope cutthroat trout—and I note that the Gold Creek population, already, appears likely to have been compromised —I’m also concerned for the welfare and wellbeing of grizzly bears and other rare terrestrial species. I don’t know if grizzly bears den on Grassy Mountain, but they’re present in the area, and appear, already, to be living within habitat in which the linear disturbance density exceeds a level deemed essential to the bears’ long-term survival. Where are the known grizzly bear denning sites, and how is Benga proposing to protect them? How can Benga mine a mountain while reducing the existing level of linear disturbances?

I love and value the headwaters of the Oldman Watershed (part of the South Saskatchewan Watershed). It was the raw beauty and ecological appeal of this landscape that, nearly forty years ago, caused me to move here. Sadly, it’s been the subsequent—and needless—degradation of this priceless land that, increasingly, has caused me to be in perpetual retreat from the land at my doorstep. Today, to a large extent, I seek recreational and spiritual virtue elsewhere (often in protected landscapes in Montana).

I have grave concerns with respect to the proposed mining of coal on Grassy Mountain and believe the following aspects of the environment are more than likely to be affected by the proposed project if it is allowed to proceed: 1. Headwaters health and integrity, particularly as it relates to threats of sedimentation, selenium, nitrates and erosion 2. Water, both qualitatively and quantitatively, for society and for the ecological integrity of native species 3. Threatened native trout species, particularly pure-strain westslope cutthroat trout in Blairmore and Gold creeks 4. The “mountain removal” aspect of the proposal is one thing, its cumulative impact on the land is another 5. The network of linear disturbances on the land already exceeds thresholds considered tolerable for some species 6. Aesthetic values within an internationally revered and marketed Crown of the Continent landscape 7. Air quality, perhaps particularly as it relates to an area that experiences regular hurricane-force winds 8. Noise pollution, its impact on humans and wildlife 9. Health and safety of the populace and indigenous flora/fauna 10. Grizzly bears and native trout should be at the top of the special-species-of- concern list My wife and I live on the eastern flanks of the Livingstone Range. The range blocks our view of Grassy Mountain. It’s out of sight, not out of mind. Particularly disturbing is the unanticipated discovery that we, at our home, have been subjected to a droning 22 industrial noise associated with the proponent’s recent exploration work on Grassy Mountain. We never anticipated this outcome.

The community of Crowsnest Pass, set amid some of Canada’s most spectacular scenery and surrounded by stunning mountain ranges, has endured the ravages of industry’s failure to save and safeguard the headwaters landscape. Scars from the unreclaimed abuses of open pit mining are visible from space on Tent Mountain and Grassy Mountain, and other mines in the headwaters of the Crowsnest River valley reveal similar degradation, i.e., there is, perhaps, no “finer” example of the government’s appalling and continual failure to monitor and control industry—and destructive recreational activity—than the land surrounding the proposed project, no more compelling reason to do far more to protect the environment than has been done before.

Crowsnest Pass is the lowest trans-Rocky Mountain pass between New Mexico and Jasper National Park. This low elevation pass, and the adjacent low passes (Tent Mountain Pass and Deadman Pass) form an incredible through-the-mountain-range conduit for species dispersal. This pass is likely responsible for the presence of bull trout and westslope cutthroat trout in Alberta, and for west-to-east plant colonization. The forests in the headwaters of the Crowsnest River are Alberta’s rarest, most diverse, most threatened, and home to tree species that are found nowhere else in the province. The preceding forms a footnote of sorts, and says this: Expect to find the unusual, the unexpected and the unlikely in the landscape surrounding Grassy Mountain.

Sadly, it’s likely that society knows more about what’s under the ground in the greater Crowsnest Pass than it does about what’s living on the surface.

Alberta’s capacity to be “open for business” needs to be reined-in to align with the environment’s capacity to make business possible without degrading life for the people of Alberta, and without constantly devaluing the environment and reducing its capacity to maintain its intrinsic—naturally given—ecological health.

The bottom line: Alberta’s headwaters landscapes must be treated as ecological gold mines. And water on Alberta’s Eastern Slopes is gold. It’s priceless, it’s rare and it’s increasingly in peril. We can’t allow it to be stolen or squandered.

Alberta and Canada need to demonstrate, to Albertans, the Canadian populace, and to the world, that the elected government is capable of governing Canada, and saving Canada for the people of Canada.

Desired outcomes: Please register and add my submission to your file. The submission supports the need to hold a public hearing prior to the release of a decision by the AER. I stand in opposition of the proposed project because I do not believe it reflects society’s goals; it detracts from the vision of recently-created parklands on the same headwaters landscape; and I don’t believe it can possibly deliver its stated 23

production goals without compromising and further degrading the aesthetic and ecological integrity of the land.

Sincerely,

David McIntyre

David McIntyre

Dear Benga Mining Ltd. and the Alberta Energy Regulator (AER): 24

Following is my SOC in print form. It’s followed by an attached document containing the same text:

December 8, 2017

Authorizations Branch Alberta Energy Regulator Suite 1000, 250 – 5 Street SW Calgary, Alberta T2P 0R4 Fax: 403-297-7336 email:

Benga Mining Limited PO Box 660 12331 – 20 Avenue Crowsnest Pass, Alberta T0K 0E0 Attention: Cal Clark

Re: Applications 1844520 and 1902073

STATEMENT OF CONCERN AND OBJECTION REGARDING: Applications No. 1844520 and 1902073 Riversdale Resources / Benga Mining Ltd. - Grassy Mountain Coal Project

Personal Information:

Statement filed by: David McIntyre Statement of Concern Filed : Dec. 8, 2017 Contact Information:

email: Land location: S1, T8, R3, W5th (approximately 12 km east of Grassy Mountain) 25

STATEMENT OF CONCERN Addressing Benga Mining Limited’s proposed Grassy Mountain Coal Project

The Benga proposal: Benga Mining Limited (Riversdale Resources) proposes to construct an open-pit coal mine, a coal processing plant, a rail load-out facility, and a new rail line. The proposal also calls for use of Crown lands and the capture, collection, and treatment of surface runoff and groundwater; the transfer of surface water licenses; the diversion of surface water; and the transfer of water from municipal to industrial use (with the end use being coal-washing and mine operations).

Problems associated with accessing Benga’s application: After seeing the Benga/Riversdale Grassy Mountain Coal Project application advertised, I drove into Crowsnest Pass to acquire a copy. The office was closed. A day later, I made a repeat trip. The office was open, but staff did not have copies of Benga’s application available for public viewing. My request was treated as if it were too costly, outside Benga’s responsibility, and beyond its ability. Later that day, after I made a second trip to the office, I was given a zip-drive containing the application.

How did other people and organizations seeking the Benga application fare during the brief window of opportunity that was provided? (I recall a similar problem during Benga’s 2015 application. It’s my recollection that, at that time, the Benga/Riversdale office was closed for an extended period, a window of time that coincided with the public’s brief pre- Christmas opportunity to comment.)

Proposal-specific concerns: The Benga-envisioned open-pit mine is located on Grassy Mountain (in the MD of Ranchland), but the proposed land use area extends south into the Municipality of Crowsnest Pass, and it lies immediately upstream and upwind of the MD of Pincher Creek.

Two streams (Blairmore Creek and Gold Creek) flow south from the flanks of Grassy Mountain. Each is home to pure-strain westslope cutthroat trout, an already threatened species that, in Alberta, is living on approximately five percent of its historic range. One fisheries biologist has referred to these trout as “dead fish swimming.” Another fisheries biologist, more 26 blunt in his assessment, described the plight of these native trout to me this way: “They’re !”

The two creeks flow into the Crowsnest River, a world-renowned trout fishery, and one of the primary tributaries of the Oldman River.

The community of Crowsnest Pass, set amid some of Canada’s most spectacular scenery and surrounded by stunning mountain ranges, has endured the ravages of industry’s failure to save and safeguard the headwaters landscape.

Scars from the unreclaimed abuses of open pit mining on Tent Mountain and Grassy Mountain are visible from space. Other mines in the headwaters of the Crowsnest River valley reveal similar degradation. There is, perhaps, no example more potent in its revelation of the government’s appalling and continual failure to monitor and control industry—and watershed destroying recreational activity—than the land defining and surrounding the proposed project. There is, as a result, no reason more compelling to do far more to protect the environment than has been done in the past.

Crowsnest Pass is the lowest trans-Rocky Mountain pass between New Mexico and Jasper National Park. This low elevation pass, and the adjacent low passes (Tent Mountain Pass and Deadman Pass) form an incredible through-the-mountain-range conduit for species dispersal. Crowsnest Pass is likely responsible for the presence of bull trout and westslope cutthroat trout in Alberta. A post-Pleistocene ice dam near Elko, BC backed up water and flooded the Elk River valley, creating a vast lake. Its outlet: Crowsnest Pass. There, as the envisioned picture unfolded, bull and cutthroat trout from the Elk Valley swam over the Rocky Mountains and entered present-day Alberta.

Crowsnest Pass is a trans-Rocky Mountain conduit for the west-to-east dispersal of flora, and for the introduction, in Alberta, of plant species that, rare or nonexistent elsewhere in Alberta, can be found in the headwaters of the Crowsnest River.

The forests in the headwaters of the Crowsnest River are Alberta’s rarest, most diverse, most threatened and, while widely known to harbor endangered limber pines and whitebark pines, are also home to extremely 27 rare (in AB) tree species that are found nowhere else in the province. Here, there are naturally occurring ponderosa pines and western white pines, black cottonwoods and more. The headwaters of the Crowsnest River are also home to Canada’s easternmost western redcedars (trees that aren’t true cedars, but are commonly called “cedars”).

The preceding forms a footnote that screams this: Expect to find the unusual, the unexpected and the unlikely on the landscape surrounding Grassy Mountain.

Within this ecological gold mine, where grizzly bears roam, where wolverines lope past stands of ancient endangered pines, where threatened native trout live within a virtual raindrop of their historic range, it is imperative that no activity be allowed to further compromise the frail thread that sustains life that, today, is already at-risk.

If society is going to protect at-risk species, the best and most efficient means of accomplishing this is to prohibit activities that further threaten already-at-risk species and the critical habitat that sustains them.

It is not acceptable to allow for known-to-be-compromising activities and projects to proceed … and then wait until activity occurs that exposes and, only then, enables documentation of the long-anticipated failure. (This is the bleak, lifeless picture that chronicles and paints our past.)

I am directly affected by the proposed project: My wife and I live east— downwind!—of Grassy Mountain, and we have already been subjected to industrial noise from its developmental stage. We’re typically outdoors, on the land daily. During past decades we’ve likely skied, snowshoed, paddled and otherwise traversed as much of the Oldman’s storied headwaters as any living couple.

I assume an active role in reviewing and assessing the impact of proposed development within the greater Oldman watershed’s internationally acclaimed and marketed Crown of the Continent landscape. I believe the region’s populace and its most viable long-range economic potential are best served by preserving the land’s world-class beauty and its ecological diversity. These raw and regionally defining natural elements constitute the gold standard that, today, paves and exposes a road to future prosperity. 28

Water, too, is gold. Headwaters health and integrity are essential to a sustainable and prosperous tomorrow. Water must not be stolen. It must be protected, too, from multiple threats including sedimentation, selenium, nitrates and erosion.

Interestingly, and alarmingly, Benga’s coal lease holdings, and other coal lease properties, extend far from Grassy Mountain and, if mined for their coal, appear destined to threaten wild-land vistas throughout the greater Crowsnest Pass, a community with one of the world’s most striking mountain backdrops.

Crowsnest Pass has the potential to reap long-term profit by saving its rare and priceless gift of natural capital and utilizing it for perpetuity via catch-and-release tourism, i.e., tourism that results in no harm to the land and the watershed. At the other end of the spectrum, some people may gain short-term economic benefit by squandering the described long- range vision and embracing industrial projects that degrade tourism, lower property values, and compromise residents’ quality of life … and their health.

Crowsnest Pass’ current tourism revenue—I’ve referred to it as nickel-and- dime tourism—is the product “achieved” following decades in which the community failed to articulate a defining vision for its future. It’s tourism that lives in the ashes, dust, and mud of recreational and industrial abuses. A look down “main street” reveals its economic worth.

Countering this vision, the Jackson Hole Chamber of Commerce has (twice) visited Crowsnest Pass to apprise elected officials and business leaders that they, like the residents of Jackson Hole, have a drop-dead- gorgeous land base, the foundation for a multi-billion-dollar brand of economic success. Pass residents were told that they had the potential to become a perpetual business center and playground for billionaires. Pass residents, in case they couldn’t see it for themselves, were told they were surrounded by a rare, world-class brand of natural capital, but that they would benefit from it only if they saved it, aesthetically and ecologically.

Crowsnest Pass, to profit from this vision, would need to protect its priceless headwaters. 29

Should the community of Crowsnest Pass decide to brand itself in this manner, it might, for a single, defining vision, give passing consideration to the drop-dead gorgeous, heralded power peak that, for millennia, has turned heads and punctuated the skyline … the peak that, surrounded by mountain ranges, stands alone to command supremacy amid the stunningly beautiful headwaters of the Crowsnest River.

This iconic, one-of-a-kind, quintessential landmark—it’s the focus of vision quest sites throughout southern Canada—is so grand, sublime and strikingly unusual in form as to be instantly recognizable to anyone who's seen it, and profoundly compelling to those who have not.

Prehistoric vision quest sites on the Livingstone Range overlook Grassy Mountain and focus on this iconic power peak. It’s name: Crowsnest Mountain.

Eminent geologist, George Dawson, a towering figure in Canadian history and science, travelled widely across North America during a lifetime of exposure to nature's most dramatic landscapes. Generations of international scholars have lauded his work, and countless Canadians have referred to him as a national hero. On the day of his death (1901), Dawson penned his last words. He described, from among the countless places he'd been, an 1880s trip into the greater Crowsnest Pass.

Dawson, valiantly searching for a "good morrow" while on his deathbed, recalled the day he camped near today's AB/BC border, witnessed a grand auroral display, then woke and headed east. There on the trail shortly after sunrise, Dawson, riding his horse Samson, ascended a ridge to a high point and witnessed "a view like no other."

Dawson's remembered "good morrow" likely placed him on the cliffs above the north shore of Crowsnest Lake. His poignantly described "view like no other" was almost certainly the sublime form of Crowsnest and the Seven Sisters, framed between the Flathead and High Rock ranges, the Livingstone Range in the distance.

This is the brand George Dawson took to heaven.

An active coal mine within this viewscape and at the gateway to the newly designated Castle Park would devalue the community and the park. It 30 would degrade the park at its point of entry. How could anyone think it would not?

What have Crowsnest Pass councils, past and present, done to explore the value of being the type of park gateway community that Jackson Hole, Wyoming is to Grand Teton National Park? (Teton County—it surrounds Jackson Hole—is one of the richest per capita counties in the US. It’s a place billionaires work and play.)

Mining in the nearby Elk River valley of southeastern BC has exposed the threat generated by high concentrations of selenium. Essential in small amounts, selenium can prove lethal, perhaps especially to salmonids such as bull trout and cutthroat trout. Selenium is a huge issue—it may not be mitigable—in the Elk River. The Benga-proposed open-pit mine in the headwaters of the Oldman River, within the same geological formations found in the neighboring Elk River valley, can be expected to generate the same results: elevated selenium concentrations that degrade the health and wellbeing of aquatic life, terrestrial wildlife, livestock and humans. Additionally, the Oldman’s lesser flow rates suggest that selenium concentrations here (in AB) could be much greater than those found in the Elk River. The killing effects of selenium on trout are typically time-delayed in the sense that the population becomes reproductively dead even as individuals, still swimming, live out their lives in dying streams. (Picture the previously described “dead fish swimming.”)

A river of wind known as the Livingstone Wave surges over Grassy Mountain and, immediately east, the crest of the Livingstone Range. This riptide of flowing air is the aerial equivalent of tumultuous whitewater. It shapes the floral community in its path and, in winter, opens critical rough fescue rangelands to herds of foraging cattle and a Serengeti-like abundance of native ungulates.

The Livingstone Wave provides free lift and transportation for another wildlife spectacle: the world’s greatest concentration of migrating golden eagles. Piitaistakis (The Place of the Eagles) is a featured site on the National Geographic’s Crown of the Continent Geotourism Mapguide. What do visitors see from this internationally marketed tourism venue? Grassy Mountain.

31

Thousands of eagles and countless additional avian migrants ride the described freight-train of wind past Piitaistakis. So does an international cadre of sailplane pilots. They, sometimes soaring with migrating raptors, “surf” the lenticular clouds that define the crests of colossal standing waves … and soar into the stratosphere. It’s here that Canadian high- altitude flight records are set.

This hurricane of wind, as it slices to the east across Grassy Mountain, can be expected to transport dust, coal fines, and any toxic wastes tens of kilometers to the east. The envisioned depositions, in winter, would accumulate on snow, where their solar-induced heat absorption would accelerate snow-melt and, as a result, diminish mid-summer and autumn stream flows. (Bull trout, another native and threatened trout species, spawn in the fall. Big bull trout lurk in the plunge pools of the lower Crowsnest River, and elsewhere within the upper Oldman watershed, including Daisy Creek, its headwaters to the near north of Grassy Mountain.)

Wind transports sound. Already, disturbingly loud and droning industrial noise from exploratory operations at the proposed mine has invaded the peace and tranquility that, historically, has characterized life for residents living along the eastern flanks of the Livingstone Range.

My wife, hearing impaired, wears hearing aids during her normal work day. She does not wear these aids while out on the land near our home. Yet it’s here at our doorstep in the headwaters of Rock Creek that Benga’s exploratory work has already negatively impacted her life, and mine. My wife describes days in which the noise, an unrelenting low-level engine sound, is particularly disturbing. She says this: “It’s an invasive, industrial droning that, disquieting and continuous, feels like it is going through my body. It’s like a toothache, constant and nagging. It disturbs my inner harmony and balance. As I walk, my mind is drawn back to the irritating noise over and over. It destroys my focus.”

The MD of Pincher Creek, in a recent survey of its residents’ values, asked them what they valued most about living where they do. The 60-page report, published in 2012, revealed that protecting the natural environment, maintaining natural wildlife and fish populations, and setting aside land in an undisturbed state for habitat protection were among residents’ greatest values. “Beautiful scenery” was identified as the best thing about living in 32 the MD. Among the residents lauded social virtues: “quality of life” and “peace and quiet.”

Rock Creek, its headwaters framed within forests of endangered limber pines and whitebark pines, is another refuge for already-threatened, pure- strain westslope cutthroat trout. My wife and I live within a stone’s throw of the creek. It emerges on the eastern flanks of the Livingstone Range just five kilometers—downwind!—from the proposed project. The concern: fish-suffocating sedimentation, airborne toxins, reduced summer stream flows, elevated summer stream temperatures, and the combined impacts of all of the preceding on today’s existing, already-at-risk, on-the-brink native trout.

Blairmore Creek has been exposed in social media circles in recent days due to its overnight transformation—as was documented on April 13, 2017 —from a clear-flowing stream to an orange, nightmarish mess. Did this problem not originate on Benga property? Might Benga’s borehole drillings —open conduits into the mountain—be responsible for the resultant discharge, and what do intra-mountain and/or in-stream piezometers and/ or water-flow gauges do to reveal the source of the observed problem? Was human health and/or stream health impacted and, if so, how far downstream? Did the problem extend into the Crowsnest River, as water- color observation would suggest? What do toxicology reports convey, and was this issue as benign as Benga’s and the AER’s public statements report, and what has the project proponent done to ensure that events such as the one described don’t reoccur?

Benga’s proposed land clearing and industrialization of the Blairmore Creek valley, if permitted, is certain to further degrade critical habitat for the stream’s native trout. Thermal and flow regime alterations are virtually guaranteed. Can anyone suggest, honestly, that sediment loads would not increase?

The entire headwaters of the Oldman watershed (including the Castle, Crowsnest, and upper Oldman), already subjected to what might be termed schizophrenic extremes in water flows—cyclic droughts and floods chronicle the Oldman’s recorded history—is extremely vulnerable to flash flooding. This is particularly true within an industrialized and heavily scarred landscape. The proponent’s proposed sedimentation and surge ponds, were they built, would need to withstand weather-related outcomes 33 in which precipitation and/or cascading snowmelt events can be expected to exceed any levels previously recorded. Climate change modeling forecasts this precise outcome.

Issues in Gold Creek, too, have been exposed in social media in recent days, but my introduction to grave concerns with the creek’s health go back to a 2015 John Wort Hannam concert in Crowsnest Pass. On July 30th, as the crowd assembled, two seasoned angling friends walked through the doors. One of the men came over to me and, with pained words, told me that the duo, after spending a day fishing Gold Creek, knew that something terrible had happened to the fishery. “Most of the trout are gone,” he told me. I knew, from those few words, that he knew what he was talking about.

Since that time, I’ve learned that here have been formal investigations addressing the issue, some by the proponent (Benga), some by the AER, the Department of Fisheries and Oceans (DFO), and Environment Canada.

An independent researcher has also reported observations during the same time period, and these reports, as I understand outcomes, have been forwarded to the same (named above) parties as well as Alberta Environment and Parks.

What seems clear—based on revealing date-stamped images—is that a large debris flow containing coal fines cascaded down the eastern flank of Grassy Mountain, entered Gold Creek and, swept downstream, was deposited throughout the length of the creek and into the Crowsnest River.

The 2015 event, believed to have originated on the proponent’s Grassy Mountain property, appears to have killed most of the stream’s trout, presumably via suffocation. Dead or dying trout can be expected to have been swept downstream and consumed quickly by a host of predators and/or scavengers.

Benga’s report of this incident and the AER’s report, mirroring each other, deliver outcomes that are at variance with the data provided by the independent researcher and appear to be at variance with hydrological data as recorded by Alberta Environment and Parks. It’s imperative that the noted inconsistencies are examined, and that the defining truth be revealed and delivered as part of the public record. 34

Trout are not my sole water-related concern.

I am opposed to the inappropriate transfer of water licenses within the already over-committed Oldman watershed, and to the inter-basin transportation of water. I am also opposed to the transfer of licenses from municipal to industrial use within the headwaters landscape. Each of these outcomes would appear to be irresponsible, a direct affront to the long- range health and wellbeing of the directly impacted populace and society as a whole. Exacerbating the issue, the proposed transfers appear particularly ill-advised when climatologists and hydrologists are projecting continued diminishment of available water from within the Oldman’s already over-allocated supply.

Last year a wildfire in northern Alberta burned through the boreal forest surrounding Fort McMurray. Nearly 90,000 people were forced to flee their homes and places of work. Smoke turned day into night. More than 5,600 square kilometers of landscape burned and 2,800 homes and buildings were destroyed. The cost of the fire is expected to approach nine billion dollars.

Officially, the fire was known as the Horse River Fire, but many firefighters referred to it as “The Beast.” Whatever you call it, it’s the most costly natural disaster in Canadian history.

Extremely costly wildfires such as the Slave Lake Fire (2011) and the Horse River Fire (2016) are being looked at by wildfire specialists as the new- normal. They’re a product produced by decades of costly fire suppression, the effects of climate change, and a human populace with an ever- expanding footprint imbedded in forests and other flammable landscapes.

The Lost Creek Fire (2003) exposed Crowsnest Pass residents to this new- normal. More significantly, the fire didn’t end the community’s vulnerability to wildfire.

The nearby Kenow Fire (2017) in Waterton Lakes National Park exposed area residents to wildfire's continued threat and, more than the Lost Creek Fire (a wildfire that, thankfully, didn’t occur during a period of high winds), demonstrated the inability of firefighters to control wind-driven fires in fuel- rich, tinder-dry forests and grasslands. 35

The Crowsnest Pass’ notorious winds appear to be increasing in speed and frequency. A downed power pole is believed responsible for a recent (October of 2017) wildfire that, fed by 130 km/hr. winds, threatened the entire community, and could easily have swept through the community of Crowsnest Pass and spread into the MD of Ranchland and the MD of Pincher Creek.

What happens when a wildfire ignites coal, or coal seams? The picture: ugly. Some coal seam fires have been burning for decades, others for centuries. Burning Mountain, in Australia, has been ablaze for a reported 6,000 years. Burning coal spews poisonous gasses. Once underground, coal seam fires are virtually impossible to put out. Teck Resources knows this well.

If Benga were allowed to construct rail lines running north - south through fire-prone, fuel-rich forests that are regularly exposed to hurricane-force westerly winds, it’s logical to assume the activity would increase the threat of wildfire, increase the potential to ignite vast quantities of mined coal, and set the stage for fire to enter coal seams. Looking within this same picture, it’s possible that, if Benga has not properly capped its exploratory boreholes, they might prove capable of providing a wildfire with deep- seam access coupled with an available supply of oxygen.

The existing threat of wildfire on the greater Crowsnest Pass landscape would be greatly exacerbated by an open-pit coal mine on the Grassy Mountain landscape. How might a coal-fueled wildfire on this landscape impact the people of southern Alberta, and perhaps elsewhere?

A 1960s coal seam fire in Centralia, Pennsylvania has transformed a thriving community into a ghost town. There, poisonous gasses still pour from a fire that, roughly 100 meters below ground, is approximately 12 km in length. The fire is expected to burn for at least two centuries.

Alberta’s capacity to be “open for business” needs to be reined-in to align with the environment’s capacity to make business possible without degrading life for the people of Alberta, and without constantly devaluing the environment and reducing its capacity to maintain its intrinsic— naturally given—ecological health. 36

It’s worth reiterating that Alberta’s headwaters landscapes must be treated as ecological gold mines. Water on Alberta’s Eastern Slopes is gold. It’s priceless, it’s rare and it’s increasingly in peril. Society can’t allow it to be stolen or squandered.

Alberta and Canada need to demonstrate, to Albertans, the Canadian populace, and to the world, that the elected government is capable of governing Canada, and saving Canada for the people of Canada.

Desired outcomes: Please register and add this Statement of Concern to your file.

This submission supports the need to hold a public hearing prior to the release of a decision by the AER.

I do not support the Benga-proposed project because I believe that it, if approved, would compromise the health and quality of life for area residents. The Benga-proposal, if realized, would, I believe, also detract from the vision of recently-created parklands on the same headwaters landscape, degrade critical habitat, and result in health problems and a deterioration in the wellbeing of aquatic and terrestrial life.

I do not believe the proposed project can deliver its stated production goals without gravely impacting the aesthetic and ecological integrity of the surrounding landscape and the vital, life-sustaining headwaters of the Oldman watershed.

Sincerely,

David McIntyre, MSc

The document:

David McIntyre 37

38

From: David McIntyre Sent: Wednesday, September 4, 2019 6:40 PM To: Grassy Mountain (CEAA/ACEE) Subject: Upcoming site visit and aerial tour of the proposed Grassy Mountain Project Dear Joint Review Panel, Thank you for, again, opening the door to the public and its ability to provide you with additional comment as you prepare for a late September site visit and aerial tour of the proposed Grassy Mountain Project. Please consider the following suggestions as components—and as points for documentary photography—you may wish to incorporate in your upcoming visit and aerial review of the proposed project: 1. The view looking northwest over the prehistoric vision quest sites on the summit of Robertson Peak (on the Livingstone Range) toward Crowsnest Mountain, one of the site’s view-featured “power peaks.” (Chief Mountain, in northern Montana, is another power peak viewed from this vision quest site. First Nations and the Archaeological Survey of Alberta can be consulted for further information.) 2. A view looking north up the Gold Creek valley toward Grassy Mountain that includes, in the foreground, the summit of Turtle Mountain and, ideally, the arrays of summit fissures that extend between South Peak and North Peak. This view, from approximately 2200 meters elevation, will convey the proximity of the destabilized mountain to the proposed project, and provide a “before” picture in the event that project-induced seismicity— assuming the project is approved —might be deemed to exacerbate the existing threat of the rock avalanche forecast to cascade from the mountain into the Crowsnest River valley. This same view also reveals the Gold Creek valley, home to numerous Crowsnest Pass residents and an already threatened population of pure-strain westslope cutthroat trout, a species living on just five-percent of its historic Alberta range. 3. A view, similar to the preceding, but farther west and, from the lower reaches of York Creek, looking north toward Grassy Mountain along the Blairmore Creek valley, also home to a threatened population of pure-strain westslope cutthroat trout and habitat critical to the species’ survival. This view also provides a visual picture of the project proponent’s proposal to transfer water—from municipal use to industrial use—from the York Creek watershed into the headwaters of Blairmore Creek and/or Gold Creek. 4. A view looking north toward Grassy Mountain that includes, in the foreground, the “ghost town” of Lille, a designated Provincial Historic Resource that, annually, attracts thousands of visitors. (AltaLink’s 1983 creation of a 500 kV transmission line in this area included a costly “jog” in the line to minimize its impact on the integrity of the site and what might be deemed the “Lille experience.” The townsite of Lille is the number-one hiking feature sought by visitors at the Frank Slide Interpretive Centre. 5. Views of Grassy Mountain as seen from, and including the summits of, Caudron Peak, Centre Peak, and Thunder Mountain (all within Livingstone Range Wildland Provincial Park). These views, as seen from approximately 2600 meters elevation, will convey the proximity of the proposed project to the park, and to the headwaters of Todd Creek and Rock Creek, each home to pure- strain populations of westslope cutthroat trout and habitat critical to the species’ survival. 6. The world’s greatest concentration of golden eagles—more than 1,000 have been counted in a single day—will be migrating south along the crest of the Livingstone Range during your aerial tour of the proposed project. Each component of this biannual (spring and fall) migration spans several months. The eagle migration is actively enjoyed and pursued by society, and promoted by the National Geographic Society. The most celebrated viewing site: Piitaistakis (Place of the Eagles). It’s located on the crest of the Livingstone Range overlooking the Gold Creek valley. Countless additional raptors, waterfowl, and songbirds migrate along this same route at the same time. Expect to see avian migrants during the course of your flight. You might, too, be especially mindful of how the tourism worth of this world-class migration along the crest of the 39

Livingstone Range— overlooking Grassy Mountain—might be impacted were an active open-pit mine to dominate the foreground landscape. Perhaps the most astonishing and troubling aspect of the golden eagle migration lies in the fact that it, prior to 2000, was unknown. Today, and mirroring Alberta’s ever-diminishing populations of native trout, the golden eagle population appears to be in decline as the migration is being documented. 7. As you conduct your site visit and fly over the land, you’ll almost certainly see deer, elk, moose, mountain goats, and herds of bighorn sheep. Look for foraging black bears and grizzly bears, and know that you have the potential to see cougars and, perhaps, a ridgetraversing wolverine. You’ll be traveling over land that’s profoundly rich and atypically wealthy in terms of its floral and faunal diversity. Please examine, as well, the wealth of crops that’s currently being harvested from agricultural lands along the three named rivers. This harvest reveals the land’s ability feed a hungry nation, and provide a high quality-of-life lifestyle for local producers. Sustaining the value of the existing vision and its multifaceted virtues is the goal of most MD of Pincher Creek residents, as confirmed by a recent survey. 8. September showcases spectacular displays of autumn foliage here amid what I’ve described as Alberta’s rarest and most threatened forest community. Some tree species found in the headwaters of the Crowsnest River valley are as rare (in Alberta) as sage grouse or woodland caribou. This forest, virtually unprotected and unknown to society, will carpet the land beneath you as you fly over the proposed project. What you may see, to give you a glimpse of the diversity beneath your feet, are golden-in-color, uppertimberline stands of subalpine larch—the species typically reaches peak autumn foliage in mid-September—and the even rarer (here) western larch. The latter species typically reaches peak autumn foliage in late October. What you won’t see, in all probability, are the land’s western redcedars, ponderosa pines, and western white pines, species that are living at the extreme eastern margins of their Canadian range and are so rare in Alberta they aren’t widely known to exist. 9. Autumn typically showcases the down side of the feast-and-famine river flows that characterize the arid West. The Castle, Crowsnest, and Oldman rivers are currently flowing at mere fractions of their spring flow rates. Dramatizing this, I suggest that you fly east to the point where these three rivers converge and are now impounded by the (circa 1986) Oldman Dam. What you will see there is this: Current flows from the three rivers draining into the reservoir are approximately one-third of the flow at the dam’s outlet. Net result: The reservoir level, dropping daily, is exposing mudflats that have been produced by the three rivers during the past three decades. Hurricane-force winds will, in coming months, move vast quantities of this mud and sand, sandblasting buildings and spreading this sediment tens of kilometers to the east. You might look, in particular, at the delta created by the Crowsnest River as it enters the reservoir. Within this expanding mudflat are deposits that have been carried downstream from Blairmore Creek and Gold Creek. What do these deposits reveal about industrial activity during the past century? What might they suggest will occur should additional coal mining be added to the upstream equation? Of particular concern: water quality, quantity, and the impact of selenium concentrations on living organisms. I ask that you look, too, for evidence of colossal flooding along these same three river valleys, and that you do this with the thought that, in an era of global warming, the incidence of catastrophic floods is on the rise. In addition to the preceding, I suggest there is value in seeing— and photographing—Grassy Mountain from additional perspectives. Perhaps the simplest and most comprehensive means of doing this involves a flight path that, using the northern apex of AltaLink’s 500 kV overhead transmission line in the Gold Creek valley as a focal point, provides the following: 1. A circular series of points from which images can be taken looking toward the noted point on the overhead transmission line from a flight path that, at a five kilometers distant 40 and an envisioned 1700 meters elevation (as possible), captures a complete 360° perspective of the project. Pictures taken from the major compass headings, and from every 45° between these points, can be used to create a big-picture “circle of awareness” for the proposed project and its scope. 2. Identical to the preceding circular flight path, but conducted 10 kilometers from the described point on the AltaLink transmission line, and from approximately 2700 meters elevation (as possible). This latter perspective provides visual awareness of the proposed project’s potential to transport dust and noise into the downwind landscape. (Endangered whitebark pines live close to the eastern extent of the species’ range on Grassy Mountain, and the easternmost outlier of the species’ range in Alberta occurs along the upper eastern flanks of the Livingstone Range. Limber pines, similarly endangered, also occupy this same landscape, but with a larger footprint, one that extends farther east.) The proposed flight path incorporating a 10 kilometer radius captures the headwaters of Daisy Creek and begins to expose the proposed project to reviewers as it, if realized, would be experienced by additional Alberta residents, perhaps most notably those living to the east in the MD of Ranchland and the MD of Pincher Creek. (Project reviewers might think of the destruction currently being caused by Hurricane Dorian, and contemplate the fact that hurricane-force winds, typically from the west, are a common occurrence along the Grassy Mountain and Livingstone Range landscape, and can be expected to occur throughout the envisioned lifetime of the proposed mine.) Thank you again for opening the door to further thought and input as it relates to the proposed Grassy Mountain Project. I offer, as a concluding thought, a request that you, following your site visit and aerial tour, find a way to project the land’s profound and spellbinding magnificence into boardroom meetings, and into your issue- defining decisions. Alberta and Canada deserve the best review process technology and critical analysis are capable of delivering. Future generations depend on this. Canada’s future is on the table. I wish you well in addressing the task at hand, David McIntyre David McIntyre

From: David McIntyre Sent: January 21, 2019 12:42 PM To: Grassy Mountain (CEAA/ACEE) Subject: Statement of Concern Dear CEAA, Please incorporate the following Statement of Concern submission addressing the proposed Grassy Mountain Coal Project: STATEMENT OF CONCERN AND OBJECTION REGARDING: Applications No. 1844520 and 1902073 Riversdale Resources / Benga Mining Ltd. - Grassy Mountain Coal Project Personal Information: Statement filed by: David McIntyre Statement of Concern Filed : January 21, 2019 Contact Information: STATEMENT OF CONCERN Addressing Benga Mining Limited’s/ Riversdale Resources proposed Grassy Mountain Coal Project Please accept this Statement of Concern as a reiteration of, and supplement to, my two earlier statements (Jan. 15, 2016 and Dec. 8, 2017). They were submitted to the Alberta Energy Regulator (AER) and Benga Mining Limited. (Please note that neither of these earlier statements, and seemingly many other statements, do not appear on the Canadian Environmental Assessment Agency’s (CEAA) registry. (Is this not a colossal problem, concern, and rationale for the CEAA to extend the submission period past its currently stated Jan. 21, 2019 deadline?) I remain opposed to the project proponent’s proposed: 1. Open-pit coal mine and its associated infrastructure. 2. Use of Crown Lands for the capture, collection, and treatment of surface runoff and groundwater. 3. Inter-stream diversion of surface water. 4. Transfer of surface water licenses, and the transfer of water from municipal to industrial use (with the end-use being coal-washing and mine operations). This statement is being used to reenforce the concerns expressed in my earlier statements. I also wish to request formal intervener status at any future hearing such that I can more fully present my rationale for opposing the proposed project. My focus of interest: assuring 41 the continued existence of the internationally acclaimed and marketed integrity and beauty of Alberta’s Crown of the Continent landscape. I feel it essential that this be accomplished in a way that saves and preserves aesthetic, ecological, and quality-oflife virtues for future generations, and does this while generating self-sustaining, long-range economic benefit. I believe that an open-pit coal mine on the western flanks of the iconic Livingstone Range, if approved, would produce negative impact far beyond its mapped boundaries, and that it would degrade waterways, air-quality, wildlife habitat, and human health. Nothing that the proponent has done or provided lessens the concerns expressed within my two previously referenced submissions. I believe it’s clear that the proposed project, if realized, would also detract from and degrade recently-created parklands on the same headwaters landscape. Livingstone Range Wildland Provincial Park, the most compelling example, parallels the proposed project and overlooks it. Were the mine approved, the park experience would be turned upside down, and altered in a wholesale and destructive way. An active open-pit mine would so overwhelm and consume the park setting and viewscape as to effectively erase the surrounding land’s stunning aesthetic appeal. (Reference my recently submitted images of Livingstone Range Wildland Provincial Park for an outcome-defining picture. My images appear in the CEAA registry as Doc # 148.) Replacing the current world-class viewscape, the presence of an open-pit coal mine on Grassy Mountain would “treat” park visitors to birds’-eye views of intense industrial activity, landscapetransforming impact, downwind dust, and the grinding throb of disturbing noise. Doesn’t it seem impossible that such a possibility—isn’t it unthinkably grotesque?—is even being considered? Rationale for concern The proposed project’s proponent, an Australian company, has a questionable past on the international stage, and no proven track record in Canada. It has made rather substantial financial and community-involvement investments in the community of Crowsnest Pass, but its environmental track record, in terms of accurately and factually reporting incidents, such as water discoloration in Blairmore Creek and reports of coal fines entering Gold Creek, remains a disturbing and apparent unknown. Similarly, the company’s potential to impact and degrade the environment and the health and wellbeing of the populace are not, from my assessments, reflected or mitigated by the stated strategies within the EIA, nor are they addressed adequately within its supporting documents. No meaningful rigor appears to have been applied. Simply stated, the veracity of Benga/Riversdale Resources is in question and in dire need of transparent clarification. Canadians and Albertans need to know, understand, and accept that regulatory bodies are serving the public good, rendering outcomes based on fact, cutting-edge knowledge, and accurate reporting. Two known water-based incidents, one in Blairmore Creek, the other in Gold Creek—they’re addressed in a previous paragraph—need to be investigated from a factual perspective. They also need to be examined from an ethical perspective. Why, as has been reported elsewhere, do the Benga/Riversdale Resources reports and the AER reports addressing coal fines in Gold Creek mirror each other while being at apparent variance with data provided by an independent researcher and Alberta Environment and Parks? Similarly, the AER’s independent investigation regarding Blairmore Creek’s recorded flow of arrestingly disturbing orange-colored water is also in question. What did the defining data reveal and, of even greater importance, can the review process be trusted? I note that the CEAA registry of Statements of Concern does not include a number of previously submitted concerns, including my own, and seemingly all of those sent to the AER. The fact that the CEAA registry is deficient in its reporting of submitted data presents a substantial concern, and suggests —does it not?—that the current deadline for submitting statements should be extended until such time as reviewers can see, and have time to respond to, the full spectrum of submitted 42 statements. I know that I am not alone in making this disquieting observation. My unease surrounding the proposed project extends into the realm of having it receive statements of support from what might be construed as “inappropriate” sources,” i.e., individuals and groups who may have directly or indirectly benefitted from Benga’s/Riversdale’s financial gifts to projects, community functions, and organizations. This, alone, brings into question the motivation for some of the proponents’ letters of support. Similarly, the region’s need for a sound tax base and economic viability should never be allowed to translate into myopic support for a single, government-sanctioned industrial project that requires Public Land and has the potential to degrade the environment and the health and wellbeing of its populace. This is particularly true of a proposal that requires the diversion of surface water and the transfer of water rights from municipal to industrial use, and does this during a time of increasing water uncertainty. An additional public health and safety concern: the potential for blasting associated with mining activity to trigger a long-projected rock avalanche that could cross the Canadian Pacific Railway line and Highway 3 in its traverse of the Crowsnest River valley from the fractured, destabilized face of Turtle Mountain. Society can not afford to deliver blind support to a project that has the expected outcome of degrading and devaluing—or even preventing!—other business proposals. As well, the region’s profound wealth in natural capital and its ability to generate future wealth and self-sustaining long-range economic viability from this internationally acclaimed asset would clearly be profoundly and adversely impacted were the project to proceed. Summary I do not believe the proposed project is capable of delivering its stated production goals without gravely degrading the aesthetic and ecological integrity of the landscape, the region’s long-term worth, and the vital, life-sustaining headwaters of the Oldman watershed. Sincerely, David McIntyre MSc David McIntyre 43

From: David McIntyre Sent: January 17, 2019 5:45 PM To: Grassy Mountain (CEAA/ACEE) Subject: Livingstone Range Wildland Provincial Park ... on the doorstep of a proposed open-pit coal mine Attn: Tracy Utting, Acting CEAA Panel Manager, Grassy Mountain Coal Project Dear Tracy, Thank you for calling me yesterday in response to my request for information. I’m providing the CEAA with this message, and disseminating it elsewhere, in order to help expose reviewers of Riversdale Resources' proposal to operate an open-pit coal mine with images that reveal the proposal in terms of its geographic location and proximity to Livingstone Range Wildland Provincial Park. The attached images should prove helpful. Riversdale Resources' proposal to create an open-pit coal mine in the headwaters of the Oldman watershed is likely receiving intense public interest this week, the last in which the populace has the formal ability (via the Canadian Environmental Assessment Agency) to endorse the proposal, or submit statements of concern. Deadline for submissions: Jan. 21, 2019 For questions and information addressing the proposed Grassy Mountain Coal Project: Grassy Mountain For public comment: https://www.ceaaacee.gc.ca/050/evaluations/document/125950?culture=en-CA The following images, all taken from Livingstone Range Wildland Provincial Park, provide views into the Oldman watershed’s breathtaking, world-renowned, Crown of the Continent landscape. It’s home to at-risk populations of pure-strain westslope cutthroat trout, and the world’s greatest concentration of migrating golden eagles. It’s also Canada’s premier soaring site, attracting sailplane pilots from around the world. There’s more. The Livingstone Range is home to prehistoric vision-quest sites featuring arresting views of two stunning power peaks: Chief Mountain (MT) and, to the near west, Crowsnest Mountain. (One of the prehistoric vision quest sites capturing spiritual, life-shaping views of Crowsnest Mountain reveals Grassy Mountain in the foreground.) The proposed open-pit mining of Grassy Mountain parallels the Livingstone Range and, if permitted, would be located below—and 5 km west of—the crest of the mountain range. Images of—and from—Livingstone Range Wildland Provincial Park The view looks north along the crest of the Livingstone Range in Livingstone Range Wildland Provincial Park from the northeastern edge of Centre Peak. The upper Todd Creek valley appears to the left (and right) of the pictured hiker. The Gap—the water gap in the Livingstone Range through which the Oldman River flows—is located to the near north. The Oldman River valley appears in the distance, as does Whaleback Ridge and, farther away, the Porcupine Hills. The view looks south along the western edge of the crest of the Livingstone Range from Centre Peak in Livingstone Range Wildland Provincial Park. The scarred eastern face of Turtle Mountain (source of the 1903 Frank Slide) appears left of center, and the Flathead Range—the crest of which defines the AB/ BC border—dominates the distant view. Grassy Mountain appears in the “middle ground,” and occupies the right edge of the picture, above the hiker. The view looks southwest from Centre Peak (in Livingstone Range Wildland Provincial Park) across the headwaters of Gold Creek, Blairmore Creek, and Daisy Creek. The Crowsnest River valley appears in the distance, beneath the Flathead Range, which dominates the skyline in the left side of the image. Crowsnest Mountain and the Seven Sisters appear at the upper right. Grassy Mountain dominates the “middle ground” view. Grassy Mountain, as seen from Centre Peak in Livingstone Range Wildland Provincial Park. The Flathead Range dominates the skyline in the left side of the image. Crowsnest Pass (the mountain pass itself) appears near the upper right, and the community known by the same name (Crowsnest Pass occupies the Crowsnest River valley between Grassy Mountain and the Flathead Range. Hikers take a break on the northern ramparts 44 of Centre Peak in Livingstone Range Wildland Provincial Park. The view looks north along the crest of the Livingstone Range. The Todd Creek valley lies to the immediate right (east), while the Daisy Creek valley (not pictured) lies to the immediate left (west). David McIntyre Crowsnest Pass, AB (CANADA) 45

From: David McIntyre Sent: Monday, September 30, 2019 4:08 PM To: Grassy Mountain (CEAA/ACEE) Subject: Looking west toward Grassy Mountain Dear Joint Review Panel for the proposed Grassy Mountain Coal Project, The attached pictures, perhaps quite different from those you may have taken of the proposed project during last week’s tour, look west toward Grassy Mountain from approximately 8 km east of the proposal. Grassy Mountain, while paralleling the pictured mountain range and lying to its immediate west, isn’t visible. What is visible, in addition to Livingstone Range Wildland Provincial Park (which commands both the eastern and western flanks of the pictured mountain range), is the approximate meeting place for three of Alberta’s municipal jurisdictions: the Municipality of Crowsnest Pass, the MD of Pincher Creek, and the MD of Ranchland. The attached pictures, taken September 30th, 2019, reveal: 1. The MD of Pincher Creek’s designated (2008) Heritage Rangeland Viewscape, a designation that has been similarly endorsed by the Province of Alberta, and by the federal government; and 2. A similar view of the Livingstone Range taken from a point approximately 500 meters farther east. You’re welcome to add the attached pictures to your file as you continue your review the proposed project. Sincerely, David McIntyre David McIntyre 46

From: David McIntyre Sent: May 7, 2019 8:55 AM To: Grassy Mountain (CEAA/ACEE) Subject: Wind-transported particulate matter Dear CEAA, The attached correspondence, while primarily addressing wind-transported dust from a road, contains information that conveys third- party conveyance of information that suggests, strongly, that active coal mining in southeastern BC is, via airborne transportation of coal fines and other dust, entering the headwaters of the Oldman river. Logic, founded in the prevailing and well known west-to-east flow of winds in the area, suggest that open-pit mining at the proposed Grassy Mountain Coal Project would, were it to occur, produce a profound downwind deposition of particulate matter. I’ve highlighted, in red, the paragraphs from the preceding that appear to be the most interesting in terms of your review of the proposed Grassy Mountain Coal Project: From: David McIntyre Sent: Monday, February 26, 2018 9:02 AM To: Matthew Coombs Cc: Minister Aep; Heather Sinton; Greg Hale Subject: Further to sediment concerns in Rock Creek and the Crowsnest River Matthew, The attached image was taken Saturday, February 24, 2018 on the western edge of Rock Creek at a point approximately 400 meters east of the North Burmis Rd. and 5.5 km north of Highway 3. I took the picture while snowshoeing down the creek from my home. High winds—likely in excess of 120 km/hr.—the previous day transported the pictured dirt from, seemingly, no place other than the largely snow-covered North Burmis Rd., an outcome that, were it not for the documenting picture, would likely seem impossible. What I’ve documented here is a single-day deposition of sediment that, on the snow-coveredlandscape’s surface, would appear to be the least likely day for such a deposition to appear. A day later (Sunday, February 25th) another snowshoeing trek down the Rock Creek valley on a pristine carpet of fresh snow suggested—falsely—that the pictured deposition, then sandwiched between layers of white, didn’t exist. Contemplating the preceding, I was reminded of a phone call I received last year from a near-toNanton snowmobiler. He phoned me due to something I’d written addressing headwaters sediment, and because of a connecting observation he’d made while snowmobiling in the headwaters of the Oldman River in the Tornado Pass area, i.e., near the AB/BC border. There, while on an outing with friends, one of the snowmobiles, buried in deep snow, had to be excavated. I was told that the group of Nanton snowmobilers, while digging into the snowpack to excavate a buried machine, was astounded by their discovery of layers of “black snow” within the snowpack’s profiled horizons. Their envisioned source of the sediment: coal mines in adjacent— upwind— BC. What, I’m wondering, does the GoA know about wind-borne sediment layers in the Oldman’s headwaters? (My “statement of concern” with respect to Riversdale Resources’ proposed open pit mining of Grassy Mountain addresses wind-borne—downwind—sediment, and its potential to impact snowmelt in the Oldman watershed.) A single-day’s—in mid-winter! —deposition of North Burmis Rd. road grit as found on the western edge of Rock Creek, approximately 400 meters east of the North Burmis Rd. (Interestingly, the pictured snow and grit, at first glance, looks somewhat like a LiDAR image of a mountain range.) Again, thanks in advance for your expected action, and a response to the questions posed in within my two messages addressing Rock Creek and Crowsnest River sediment, David My previous message (February 16th) addressing the same subject: Subject: Road dirt/sediment in Rock Creek and the Crowsnest River Matthew, Top of the day. It’s been some time since we’ve talked and, as a result, I’m not currently abreast of who does what in southwestern AB as it relates to fisheries issues/concerns. As an outcome of my naivety in terms of knowing the GoA reporting framework, I’ll simply toss the following in your direction with the expectation that you’ll address it, or forward it to someone who can. Here’s the issue: Recent happenstance took me to 47 the attached picture, one I took three years ago (late January of 2015). The image shows windrows of windblown dirt from the North Burmis Rd. (There’s no other possible point source for the pictured volume of dirt on the described landscape.) Windrows of wind-borne sediment from the North Burmis Rd. are seen in this north-facing view along on the western edge of Rock Creek. The picture was taken in January of 2015 at a point approximately 1600 meters east of the North Burmis Rd.—a full mile from the windblown dirt's point of origin!—and 3 km north of Highway 3. The downwind delivery of windblown dirt from the North Burmis Rd. results in what would appear to be obvious and colossal sediment loads in Rock Creek and, farther downstream, the Crowsnest River. The provided image looks north from the western edge of Rock Creek—the creek’s located at the extreme right (east) edge of the picture—at a point approximately 3 km north of Highway 3 and—here’s the amazing thing!—reveals windrows of dirt that, originating from the North Burmis Rd., are approximately—and amazingly!—1600 meters east of the road. It’s my belief that the trout population in Rock Creek has—during the two-plus decades that I’ve come to walk it and observe it on a daily basis—undergone a steady state of fisheries decline, and that, at variance with the recent past when trout were conspicuous, very few trout exist in the creek downstream from my home. (You are in possession of the results of an October of 2016 DNA trout study of Rock Creek, and I would assume this study constitutes a date-stamped and defining measuring stick in this regard.) Stream-bed road dust isn’t the only hurdle faced by Rock Creek trout, but I suggest that it’s likely to be the leading cause in stream- bed sedimentation. The southernmost half of Rock Creek—this portion of the creek flows southeast to its confluence with the Crowsnest River— lies to the east, i.e., downwind, of the North Burmis Rd. Earlier this winter, before snow covered the land and added moisture to the roadbed, I had dozens of occasions to look south along the north-south trending southern portion of the North Burmis Rd. I did this from the crest of a ridge located 2 km east of my on-the-creek home. What I saw was deeply disturbing, and it reconnected me with the attached image. What I saw was this: Each vehicle traversing the road generated dense, smoke-like plumes of dust that, spread by westerly winds, moved eastward toward Rock Creek. From my lofty ridgetop vantage point, I could see—from as much as 3 km away—thick clouds of dust drifting hundreds of meters to the east before dissipating, i.e., settling along Rock Creek. A quick check with the MD of Pincher Creek reveals that ongoing maintenance of dirt roads in the MD requires that as much as 150 cubic meters of new surfacing material/mile/year is added to the road-bed. It would likely prove to be a mathematical nightmare to compute, from the preceding, how much of the road- surfacing material “disappears” as windblown and waterborne sediment, but, again, the attached picture reveals a picture of wholesale downwind dust movement and its impact on stream-bed sedimentation. It’s staggering to visualize this: an estimated 7,500 cubic meters of fill have been added to the southernmost 5 miles (8 km) of the North Burmis Rd. during the past ten years. (This is the portion of the road that lies to the west (upwind) of Rock Creek after the primary tributaries of the creek, flowing east, cross the road and, east of the road, flow to the south, paralleling the road.) What percentage of this fill is now in Rock Creek and/or the Crowsnest River? Another dust-related concern/consideration is that dust particles on snow generate heat that melts the snow prematurely. I’ve photographed “black” snow during recent winters as I’ve hiked and snowshoed along Rock Creek, and an examination of snow drifts on this same landscape reveals layered bands of dirt sandwiched between layers that are less densely packed with grit. Whatever the measured effect of this “black” snow might prove to be, it’s certain to cause the snow to melt earlier than “usual.” thus contributing to an atypically early spring snow melt, i.e., melting that would exceed the impact of climate change modeling alone. Spring runoff, 48 historically, occurred here in mid-June. The last few years suggest that mid-April might be the new normal. What part of the new-normal is needlessly generated by dirty snow? I’m not suggesting that the southern end of the North Burmis Rd. be paved, nor do I want this. What I want—I see the following as a reasonable and appropriate request—is for the situation to be reviewed and addressed in a way that solves the described and pictured problem. Also, I suggest that fisheries biologists look farther afield to see where else similar problems exist, and where corrective action can be undertaken. Rock Creek’s status as a home to threatened pure-strain westslope cutthroats, and the creek’s potential to regain, throughout it’s length, the reestablishment of this outcomel, puts the stream on the provincial and federal radar, and sets the stage for it to be treated as a high-end benchmark from which other streams can benefit in down- the-road restoration endeavors. Thanks in advance for your expected action and stream-triage efforts, David David McIntyre 49

From: David McIntyre Sent: April 25, 2019 3:27 PM To: Claire Rogers Cc: Grassy Mountain (CEAA/ACEE) Subject: Re: Public Comment Period Claire, Your recent message, attached, suggests that Riversdale, instead of responding to my statements of concern addressing the proposed Grassy Mountain Coal Project, is naive enough—or bold enough—to propose that it can, instead of responding to my concerns in writing, throw a few informal words my way, and/ or address my many concerns via a public “chat” session. I find the proposed attempt by Riversdale to wash critical and well-articulated concerns through a brief, unrecorded exchange of words meaningless, deeply insulting, and counter to the public good. Riversdale’s action in this regard might also be seen as an intended affront to society’s critical review of facts and assessments surrounding the proposed project. David On Apr 22, 2019, at 7:43 PM, Claire Rogers wrote: Hi David, Thanks for your participation in the most recent public comment period. I have attached Benga’s response to this email. I know you have previously indicated you do not wish to meet but should you change your mind you are welcome to contact me at the information below. Thanks, Claire David McIntyre David McIntyre 50

From: David McIntyre Sent: March 19, 2019 6:18 PM To: Grassy Mountain (CEAA/ACEE) Subject: Looking south from the Oldman toward Montan's Wild and Scenic Missouri Dear CEAA, Amid ongoing concerns for the greater Oldman watershed due to Riversdale Resource's proposal to mine Grassy Mountain coal, I just received an article that addresses a pollution and cleanup bill—it’s approaching $100 million—for an abandoned mine in Montana’s Little Rocky Mountains. The article: https://www.hcn.org/articles/climate-desk-mining-companies-pollute- westernwaters-citizen-pay-for-the-clean-up?utm_source=wcn1&utm_medium=email My wife and I canoe the BLM managed Wild and Scenic Missouri River frequently, and know the mine from the views we have of it from the otherwise strikingly beautiful badlands—the Missouri River Breaks. As we canoe past the Little Rocky Mountains, the disfigured and mining-defaced landscape we see hurts at a visceral level. What we don’t see from the internationally revered waterway are the bleeding and polluted streams of orange water that stream from the mine into the Fort Belknap Reservation and its native community. This September of 2018 view looks upstream (west) on the Missouri River, and excludes the scarred face of the nearby Little Rocky Mountains. The mining scars: deeply disturbing. The article describes Pegasus Gold Corp, a Canadian company that owned the mine, went bankrupt, and folded 20 years ago leaving a legacy of water pollution and a taxpayer cleanup bill that, growing, currently approaches $100 million. From the article: “They took the heart of the mountains away from us.” “They took the heart of the mountains away from us,” said Morin, chair of the tribal council’s natural resources committee. Pegasus isn’t an isolated case. Especially in the drought-prone West, the outdated and opaque regulatory system meant to ensure money is available to restore water and land at gold, copper and other hardrock mines often falls short. Regulators with insufficient funding are tasked with cleaning up a mess left years ago by now-defunct companies. The agencies that required those firms to set aside money underestimated how much it would take, in some cases acquiescing to companies pressing for lower amounts. Pollution seeping from these mines regularly contaminates waterways. There’s often no end date to treatment costs, billions of dollars of which have been shouldered by taxpayers. David McIntyre 51

From: David McIntyre Sent: May 3, 2020 2:55 PM To: Grassy Mountain (IAAC/AEIC) Subject: Grassy Mountain Coal Project proposal Joint Review Panel Manager Grassy Mountain Coal Project 160 Elgin Street, 22nd Floor, Ottawa ON K1A 0H3 1-866-582-1884 / [email protected] Dear Joint Review Panel Manager, I (David McIntyre) am submitting the following as a complement and supplement to previous Statements of Concern: The attached pictures were taken May 2, 2020. The Livingstone Range, hidden from view during a westward ascent of a paralleling ridge lying east of it, explodes into view within a few ridge-summiting footsteps. The pictured hikers, looking past blooming wildflowers, displaying grouse and snipe, are standing in the passing shadows of overhead eagles, hawks, and Sandhill cranes. Two hikers on the crest of a ridge look west into the storied headwaters of the Oldman River … and toward “Living Stone," the knife-edged, snow-white flyway that defines the spring flight path of the world’s greatest concentration of migrating golden eagles. A similar view from “Raven’s Outpost” Here’s what you can’t see in the attached images: the colossal threats to aesthetics, quality-oflife, peace and tranquility, and ecological integrity imposed by proposed open-pit coal mines to the land immediately west of the pictured views … and to the downwind and downstream watershed (on which the pictured hikers are standing). David McIntyre 52

Submitted May 5, 2020

1 Canadian Impact Assessment Registry Reference Number 80101 Grassy Mountain Coal Project Crowsnest Pass, AB Written request to participate in the Joint Review Panel Hearing Please accept this document as a confirmation of my intent to participate in the Hearing. Nature and Scope of my Intended Participation 1. I live 12 km downwind (east) and downstream from the proposed open-pit coal mine. During its exploration process, industrial activity generated disturbing, low frequency, daylong noise—it was transmitted across the land with a deep, droning, vibrational component—that stole my ability to enjoy my property and any outdoor activity. The potential for the proponent’s application to be approved presents a quality-of-life- threatening thought that, even in its conceptual stage, forces me to contemplate the realization that my hard-won home and an idyllic retirement property could effectively be taken away from me by a project I can’t quite see, but that, due to its known and unknown ability to generate impact far beyond its defined borders, is frighteningly too close. My wife and I live an Edenesque, quality-of-life existence on Rock Creek (home to a threatened, pure-strain population of westslope cutthroat trout) and look out on the natural beauty of the area. We also, daily, are on the land, hiking extensively along the Livingstone Range and elsewhere within the headwaters of the Oldman watershed. I am gravely concerned by the thought of the proposed project and its, if approved, guarantees of industrial noise and windborne dust to a land well known for its all-too- regular hurricane-force winds. The proposed project also threatens an entire downstream watershed, and has the potential to trigger rock avalanches, including the long-forecast “second coming” of the Frank Slide from, already destabilized, Turtle Mountain. 2. I plan to read a submission that defines my personal concerns and frames them within my extended multidisciplinary science-based university studies and a career that includes serving as a study leader for the Smithsonian Institution, where I led multi-day field trips throughout the US West and the Canadian Rockies. 3. Contact Information: David McIntyre,