Melanie Daneluk
From: Robert Axten [[email protected]] Sent: Monday, February 26, 2007 7:55 AM To: [email protected] Subject: Proposed Dodd's Roundhill Coal Gasification Project
To whom it may concern:
I am writing to express my concern over the Dodd’s Roundhill Coal Gasification Project. I am a resident of the Kingman area and have read both the Public Disclosure Document (dated January 27, 2007) and the Proposed terms of reference. I have also attended a community meeting held at Roundhill February 15, 2007 where practically all those in attendance voiced their concerns as well. These concerns are numerous and wide ranging. I will summarize the key concerns in the following two categories; Environmental and Socio-Economic.
1. Environmental
First and foremost is the concern of water usage by the proposed development. It is documented that up to 9.5 million m3/year per gasification plant could be used. (This quantity is multiplied by 4 if full potential expansion occurs) This is not good news In an area with an already depleted/damaged water table. If a pipeline from the North Saskatchewan is envisioned, there is also cause for concern during low flow periods.
The prospect of eliminating all existing coal seams underground in the area will severely disrupt underground water flow to the Battle River basin which in turn will negatively affect communities downstream who depend on this river system.
The numerous waste effluent streams, and air emissions need to be scrutinized with plans not only for their transportation and storage, but also detail plans for emergency situations and compensation to residents. Accountability must be guaranteed and mitigation strategies in place beforehand.
Disruption of all wildlife and vegetation needs to be studied in great detail. Local parks, wildlife sanctuaries will be severely damaged by such widespread ‘clearing’ of landscape. Soil erosion, wind patterns, and microclimates will be altered for very long periods of time.
2. Socio-Economic
Adequate compensation to all landowners needs to be addressed in far greater detail. What is ‘fair market value’ for a lifestyle when no equivalent situation re: land/housing can be immediately obtained? The quality of life especially for those living in the coalmine area will be negatively impacted in the long term by heavy equipment noise and traffic on rural roads. Also of concern are the numerous industrial installations, pipelines, rail lines, and large scale utility infrastructure requirements.
In Alberta for the foreseeable future, any additional large scale skilled labour force is in short supply. The existing labour/housing situation can be exacerbated by a project of this magnitude. Almost unanimously, all people present at the community meeting agreed that a job in a coalmine was not a good substitute for making a living off their own land. Who really benefits from the project? Will the supposed economic benefits stay in the community?
The last point I would like to make what affect this proposed project will have on the history of the area. There are several Century Farms along with historic buildings, cemeteries, and view corridors. Once these have been displaced, the connection of people to place is lost. This point has been made by a number of rural families in the area. We have to protect what is remaining of Alberta’s rural heritage and give some serious thought about how badly Alberta needs this project.
The above points illustrate what many local people are genuinely concerned about. Extensive and detailed studies must take place for all pertinent issues in order to adequately assess the impacts of such a massive and physically disruptive project. I also firmly believe that real sustainability is achieved through protecting ways of life and the land which will provide it for future generations.
11/6/2009
Yours truly,
Robert Axten,
B.Arch, RIBA, Leed Accredited Professional.
11/6/2009 PAGE 02/05
February 19/07
ATTN; Director. Environmental AsseesSs.ment,Central Re-qi-on
To whom this may concern, Regional Sewices RE: Promsed D0dd.s-Roundhill Coal Gasifcation Ptqiect Central Region
I am writing to express my concerns regarding the proposed Coal Gasifcation Project by Sherritt in my community of Tofield, Alberta.
This company has recently presented their public disclosure on this project, and I am deeply alarmed with the environmental ramifications of it! Specifically, with the proposed j.2.,500 tonnes of greenhouse gas emissions per dav that Sherritt is openly estimating. With the increased'attention to our environment of late, Iam horrified by this staggering number. Reducing Canada's emission levels is an undeniable priority to every politician and every citizen in this country. Our world depends upon every country participating, and I cannot see how this project will support any of the goals stated by our provincial or federal governments.
The magnitude af this project is astounding, especially in regard to the devastation it will cause to the land, which, we are told will be "reclaimed" and more importantly to the water aquifer, which can nevec be restored! With all due respect, the land can never be reclaimed to its original beauty and productivity. And how does Sheritt propose to replace the water aquifer, which runs toward Beaverhill Lake and nurtures and feeds streams and wetlands in this huge area? It cannot be done and would be destroyed forever.
This project wuld be happening literally in our back yard -we could not live here in such close proximity to the noise and incredible filth that the mining would bring. In the public disclosure document words such as "open pir, "mobile fleet of heavy equipmentp, "draglinen, "rail facilitiesn, hardly inspire confidence in the preservation of any environmental integrity. Our community will be devastated by this project!
I am urging you to pmtect this land and be the defender of the only environment we have - it is a very delicate, priceless and irreplaceable thing.
RR#3 Tofield, Alberta TO0 4J0 Melanie Daneluk
From: gordon baergen [[email protected]] Sent: Saturday, February 17, 2007 12:37 PM To: [email protected] Subject: Objection to Sherritt mine development in Round Hill
I attended the Feb 15/07 resident meeting to discuss the Sherritt Dodds-Roundhill Coal Gasification development project. From my perspective, there are several major items which are not being fully addressed. These items must be resolved before any further consideration can be given to this project:
1. Compensation to land owners.
z how will FMV be established z how will residents be compensated for destruction of family history and for sentimental value z can residents be given the option of "mothballing" their residences and their operations such that they would be taken out of service while the mining operation goes on around them and until the reclamation is subsequently done to where they can resume farming operations
2. Ground Water
z mining to a depth of 40 meters will almost certainly destroy the shallow aquifers in the mined area forever. Residents must be assured that they will be provided with piped in water if satisfactory aquifers cannot be accessed for their water supply z the broader effect of such a massive ground disturbance must be understood. There must be an understanding of the radius of influence of this project and then a plan must be in place for how disturbed sources will be dealt with
I can be reached at 780 467-6559 (res) or 780 389-7154 (bus) to discuss this further.
Thank you, Gordon Baergen
11/6/2009 Melanie Daneluk
From: Beaver County CAO [[email protected]] Sent: Wednesday, February 28, 2007 1:40 PM To: [email protected] Subject: Terms of Reference for EIA (Coal Gasification Project) Attachments: Sherritt EIA.pdf
Attached is a copy of a letter that has been faxed, and will be mailed, to your office regarding Beaver County's comments on the proposed Terms of Reference for the Coal Gasification Project EIA.
Margaret Jones CAO Beaver County .
11/6/2009 Beaver tounty
BOX 140. RYLEY. ALBERTA TOB 4A0
February 28,2007
Director, Environmental Assessment, Central Region Alberta Environment 1 1 1, Twin Atria Building 4999 - 98 Avenue Edmonton, AB T6B 2x3
RE: PROPOSED TERMS OF REFERENCE FOR EIA (COAL GASIFICATION PROJECT)
Beaver County Council has reviewed the proposed Terms of Reference for the Environmental Impact Assessment related to Sherritt International Corporation's proposed coal gasification project, and requests that an assessment of light pollution be included.
Thank you.
Margaret JONES Chief Administrative Officer
PHONE:78-3-3730 FAX:780663-3602 VISIONARY AND PROGRESSIVE Website: www.beaver.ab.ca t WORKING TOWARDS TOMORROW..... cmail: administration(9beaver.ab.ca Melanie Daneluk
From: [email protected] Sent: Friday, February 23, 2007 5:04 PM To: [email protected] Subject: [SPAM-low] Fwd: Sherritt Dodds-Roundhill Gasification Project
----- Forwarded message from "Beckmann, Diane"
February 23, 2007
I am writing in regards to the Sherritt Dodds-Roundhill Gasification Project.
I believe the ramifications of this project, while giving only a short term financial gain, will have a far-reaching detrimental effect on the residents, environment, community and future generations.
I have grave concerns about the water supply and management for this project. Of Earth's water, we only have one hundredth of 1% that is in our fresh water streams and useable. Clean, fresh water is very precious and needs our protection. The area involved with the Sherritt Dodds-Roundhill Gasification Project has an increasing demand on the water supply. In drought years, the water supply has not been adequate. The flow of the Battle River varies widely because the river is prairie fed. The Battle River relies on the rain and snow and the coal seams to feed its flow. Once the aquifers have been damaged, as they would be in this project, there would be no way to ensure their restoration and they would be gone forever. The wetlands and riparian vegetation act as natural filters, storage areas, help reduce flooding and are important habitats for the wildlife. If we destroy or reduce these areas we will lose vital amounts of water stored in the shed. Since Alberta is legally responsible for 50% of the Battle River waters that go to Saskatchewan, we must be very careful. Extensive and intense research must be done involving the water issue. One stage of this project uses about the same amount of water as the city of Lethbridge.
How will the needed enormous amount of water be found to support this project?
What will happen to the people outside the region who will be affected by the loss of water?
How will the wastewater be properly managed to ensure that the clean water remains uncontaminated?
We need a replenishment of our water not more depletion.
Many of our lakes and wetlands are drying up. What will be done to remedy this?
Not only does the water issue play an integral role but also the many plants and animals in the area will be disastrously affected. The impact of the destruction of the natural habitats of many species of plants and animals will be phenomenal. The habitat will be irreversibly destroyed. Once the land has been cultivated, many of the natural grasses, wildflowers and other plants will never return to the area. While growing up in the area, I saw many of my favourite wildflowers, such as the Indian Paintbrush and the crocus disappear as more and more land was cultivated. Fortunately there are some areas of land that have been left untouched and continue to be able to sustain the natural vegetation and habitat for our animals. We have many sensitive and 1 at-risk birds, mammals and reptiles in this area as well. Many of these animals require natural habitats for their homes. They need the uncultivated land and old trees for raising their young. If we eliminate these sanctuaries of natural grasslands, stands of trees, small ponds, wetlands and riparian vegetation these animals will disappear form our area forever. This area is, also, along the migrating route of many birds. Thousands of birds come in flocks to rest and feed here, some stay, while some of them head further north. I have spotted bald eagles, herons, egrets and many other birds near our farm. Over 250 different species of birds come to Beaverhill Lake just north of the area. Changes in the environment may drastically harm the animals in this area.
The effects of this project also affect the landowners and residents. We will face a dramatic change of lifestyle. No longer will we have the peacefulness of the countryside, the thrill of viewing the flora and fauna, or the very close tie to the land and buildings. My great grandparents and my grandparents homesteaded in the area. My grandparents built and maintained the home that I grew up in. My father was born and has lived all his 87 years on that property and the ties he has are deep and strong. I grew up on our family farm and have a special attachment to the home and the carefully planted and tended trees. By the house there is a giant spruce tree that when it was a sapling my grandfather once placed his chair over to prevent children at my brother's confirmation from trampling over. There also is my Canada Centennial mountain ash from my 4-H involvement, it bursts into flowers, then produces berries for food for the birds in the winter. The lilac bushes filled with a delicious scent every June are very special. They hold a great sentimental value. The one room school that my great grandparents donated land for and my father attended is just down the road. Part of the livery barn and office that my grandfather once ran in Ryley are at the farm.
These things invoke a great sense of pride of what my family has contributed to the community and the building of our province.
It is a place that I can show my children with honour, the value of their heritage and the responsibility they have inherited to continue to support and contribute to the community.
This project would demolish the landscape, destroy homes, produce noise, pollute, increased traffic, risk possible spillage, damage the watershed, and bring desolation and despair to those who care about their homes, heritage and environment. Our land is a precious resource. The aboriginal people believe that the land belongs to everyone. Every part of our ecosystem, the plants and animals, the land and water, all play a vital role. We share the earth and need to be sensitive to it. The undisturbed beauty of the natural world has a value beyond the measure of dollars and cents.
We must be good stewards of the land for future generations.
In this day of depleting reserves, the cost of extrapolation and the exorbitant cost to the wildlife and environment need to be addressed.
We need to look forward to the future for alternative sources of energy that are clean and renewable like wind, solar, thermal and bio-fuels.
We have the knowledge and the ability to be a forerunner in the energy field.
Let us not turn a blind eye to the things has real importance.
I am convinced that this project is not in the best interests of our future.
We have only one chance to care for our environment correctly.
Let's do it with forethought.
Respectfully, Diane Beckmann Box 618
2 Tofield AB T0B 4J0 daytime phone 780-662-3010 home phone 780-662-3518
----- End forwarded message -----
3 FROM : BQSMQLTR FQRMS PHONE NO. : 403 662 3567 FEB. 26 2007 04:01PM P1
Rosrnalta Farms RR 3 Tofield, Alberta TOB 450
Director, Environmental Assessment, Centrnl Region Alberta Environment 1 I I, Twin Atria Building 4999 - 98 Avenue Edmonton, Alberta T6B 2x3
To Whom It May Concern,
Subject: Proposed Dodds-Roundhill Coal Gasificatiod Project
We received notice that Sherritt International Corporruion is proposing a coal gasification projecf in our backyard, ?%is raises a big concern to us.
We own and operate a 400 sow farrow to finish family hog far* which is located on the boundary of the proposed mine. Our main concern is WATER, WARR, WATER
Water is the lifeline of our family fm.We are concerned with what will happen to the ground and surface water.
Another concern we have is feed supply. With local land tumhg in to a mine we will be forced to ship grain from other places at an added cost, endangering the viability of our business.
The documents issued to date by Shemtf including the "Public disclosure Document" and the "Proposed Terms Of Reference for the Environmental Impact Assessment Report", clearly indicate that the local groundwater will be jeopardized.
The Terms of Reference docs not cover; The impact on mundwater levels and vressm outside of the '"Project Arm''. Project related water withdrawal is mentioned, but digging, coal removal, and aquifer disturbmces will also effect groundwater. The effect on wat.m.a& outside of the "Project Area". The water quality within the mine is discussed but the surrounding areas are not covered. Any indication that Sherritt will take responsibility for the loss of water.
Water is Alberta's most precious resource. I am requesting that you and Alberta Environment help to protect our water.
Sincerely,
Leo Bosma FROM : BBSMRLTR FRRMS PHONE NO. : 403 662 3567 FEB. 28 2007 07:43PM PI
Bosmalta Farms RR 3 Tofield, Alberta 'TO16 430
Dimtor, hvjronmental A$smmen&Central Region Alberta l%vh-t 11 1, Twin Atria Building 4999 - 98 Avenue Edmonton, A- T6B 2x3
To Whom It May Cancem,
Subject: Proposed Wds-RoundhIll Coal Gasification Project
SWahtemtional is planning a coal gasification piant and mine in our backyard, This is a majw concern.
We own 3 400 SOW famw to fmih hog this is ow @& en joy. When cod is being dug out so will the water in it . We use a wll for our livestock, it is producing lots of water. We use about 30 cubic meters of water a day. To us this is a lot of water. Our concern is hen water.
What we could not find m the dmldtltats provided by Sherritt is who is going to be responsible for the loss of wmr.
Wmr is the most precious resource of Alberta, and I ask yoti to protect it.
- Sijmen and Hermie Boma Melanie Daneluk
From: Chrystal and Owen [[email protected]] Sent: Saturday, February 24, 2007 9:45 AM To: [email protected] Subject: [SPAM-low] Proposed Sherritt Dodds-Roundhill Gasification Plant
February 24, 2007
Dear Sir/Madame,
As a resident in the proposed study area of Sherritt's proposed Dodds-Roundhill Coal mine and ICCG plant, I have several concerns with the project as it is laid out in the Public Disclosure and the Terms of Reference for Environmental Impact Assessment Report.
1. I have discovered that any attempt to mine the coal seams in this area will have the following far reaching negative implications for water:
- The Battle River Basin is a key prairie water resource that would be damaged by mining the water flowing coal seams. People living in regions as far away as Manitoba would be affected by the reduction of water flows;
- This project requires a vast amount of water to be used in the mining and gasification process. Sherritt suggests that they will procure the water from the North Saskatchewan River...or barring this...water from the Aquifers in the mining area. Further damage to the environment east of the Sherritt plant would be evidenced;
- The whole operation will have severe water implications on the habitat in the area. Beaver County is a migratory bird sanctuary with many resting water surfaces. This project has the very real potential to damage or divert the wildlife in the area through the drying up of several area lakes.
2. This project is not in the public interest. It serves purely to feed the Bitumen upgraders with syngas, which is not taking into consideration current capabilities or the changing global consciousness towards mega-projects and the resulting GHG emissions:
- An article in the June 2006 Oilweek publication states that "Coal Gasification in Alberta 'is a decade or more away'." - Carbon sequestration, as mentioned by Sherritt as a way to be a 'clean coal' plant, is not currently economical, nor viable, in Alberta. I have not yet found anyone who can say that sequestration is long term enough for the human good. Many articles state that this is not the "Silver Bullet" that the coal industry is hoping for. It seems fair to consider that the plant will be a major contributor to the greenhouse gas emissions in Alberta that are gaining a greater share of the public's attention. - CO2 for enhance oil recovery, seen as the other option to get rid of the GHG by Sherritt, is also a risky venture for the health of our planet. Again, seepage of this gas is not fully known. The Pembina Institute, amongst other Alberta research sources, has spoken eloquently on this subject and can be referenced.
3. This entire community is agricultural based and has a wonderful social fabric. I have heard that approximately 500 landowners are directly affected by this proposal. These landowners are largely farming or ranching oriented with a multitude of avenues of how they give back to the community. These landowners have been stewards of this land for their livelihood for upwards of 100 years.
4. The social impacts of this project go far beyond the displacement of families:
* Increased traffic,pipelines,heavy trucks,crime; * Increased noise in an area that was never there before, resulting in a much reduced quality of life; * Decrease in wildlife; * Potential loss of water table needed to farm or ranch; * A higher potential for ground water pollution; * Air pollution unknown to the area before the proposed plant/mine...especially for fatal illness such as silicosis, as well as overall increases in airborne pollutants; * Evidence from industry watchdogs and policing which shows that reclaimed land will be nowhere near the quality it was before, nor is it thought to be able to support the same vegetation, wildlife and buildings/ structures as it had before.
11/6/2009 5. I object to the steps that Sherritt has taken so far to make their announcement of this plant/mine. I think that an ad in the Tofield Mercury is not sufficient notice to people such as myself, and others in the province/country, who will be directly affected by this proposal. Although I am not familiar with the minimum requirements for Sherritt to reach the affected residents, I can't imagine that this is what the AEUB was studying and implementing as procedures to contact landowners in areas of heightened resource development. I am a landowner, on title, and would still appreciate a letter, as well as a copy of the Public Disclosure document, from Sherritt as one of their minimum requirements of public notification. I did not become aware of this project until earlier this month, which means that I missed both of the public meetings held by Sherritt. As I talk to others in the community about this, virtually all of them share the same experience. How many other landowners in this affected area are not aware of this proposal and it's huge implications?
Lastly, given the inadequate information that residents have received over the past several months, it seems obvious that the period from January 17th to February 28th is not sufficient time for a great number of us to make an informed decision about this proposal and to reply to the necessary decision makers. At the very least, there must be more time allowed for us all to fully understand the magnitute of this proposed project and respond accordingly.
Regards,
Owen Forster
11/6/2009 Februaxy 22,2007
Director, Environmental Assessment,Central Region Alberta Environment 11 1 ,Twin Atria Building 4999-98 Ave. Edmonton, AB T6B 2x3
To Whom It May Concern:
In regards to the proposed Dodds-Roundhill Coal Gasification Project, I, as a landowner in this area, have grave concerns about this project.
The following are a few of my concerns:
Environmental - groundwater (quality and quantity, during and after mining) - watershed area that feeds Beaverhill Lake runs through the proposed area - wildlife (you cannot put a dollar value on geese, chickadees, tadpoles and frogs, crocus, ducks in sloughs, owls, hawks, coyotes, deer and moose) - the disruption of native grasses, trees and flowers (the ecology of our land which is adjacent to the Amisk Creek) - the disruption of our good farmland - air and noise pollution associated with mining activities.
Economic - we are making a huge sacrificewhile everyone else is seemingly profiting from this project. - we question - - How can it be worth it to us? Social - loss of community - the Bardo community has been active and close-knit since its establishment in 1894. We have land that is still being farmed by descendants of the original homesteaders and if the mine goes through there will be no next generation to carry on the Bardo Community traditions and history. - we choose to live here because we feel safe and protected. Our neighbors care and look out for one another. We will lose this security if we are forced to relocate. Our community is irreplaceable and priceless!! - to keep the history of the Bardo Community alive, ow members have put tens of thousands of volunteer hours into fundraising, and upkeep of our community center. - the uncertainty of our future is creating enormous stress on the family unit including the youth in our community. - loss of homes, livelihoods, jobs, and vocations. - the future of the Bardo cemetery, which was established in 1898, is of great concern to family members.
As of today, I am opposed to this project. There are too many questions and concerns that have not been addressed to our satisfaction. We are faced with so many unknowns,our lives are left in limbo.
We see no positive outcomes at this time.
With concern, HART CONSTRUCTION
.lirn and Ri:~n~~ic:Hnrt Box 89 Tofiekl A6 TOB 4JO
To: Dlrecbr, EnvlronmenM Assessment, Central Region From: Jim and Bonnie Hart Name: Date Sent: Feb, 22,2007 CC: Phone: Number of Pages: 10 Fax: 780 427-9102
MeSSflCje: Gommal~tson Sherritf's Proposed Terms of Reference for the Envirofin~entsllImpact Assessnaent For the Ocrdda Rouncl Hill Coal Gasification Project mmen. % n thn pro Terns dRdcmeef~rthe-mnmtats~Im~eet Amment wds- Round Hiu Cml Gasifmtion PFO~&+ February 20,2007
Tho following comments and questions have been compiled ta voice out concerns hutthe proposed Tcnm of Reference for the Euvironmental lmpact Asswment for the Dodds - Round Hill Gasification Project. We are land mmin the Proposed DBvelopmat Area and fccl deeply whcdabmt the ema project of this maguitudc would have on the environment, the economy, and the people of this area Also, since this is going to be the first plant of its kind h Canada we boltcve that extra conaideration must be givcn because there ate no existing projects hmwhich infomaion about actual and cumdative e&cts am be used.
In an overall view of the Shemitt document we find that that it is very vague and genemlly unspecific in too mmy areas, especially those ieas dating with dangerous chemical pollutants, water supply and grourrkter issuos, the wel- of thc stakeholders ,plans for decmmissioningof thc project, reclamation and the eventud plans for the land.
I Shenitt representatives bave givcn us very little information so far and answer most questions with 'We don't known or give us conflicting infmation.
Wc believe we have a right to know what their plans are and on a larger scale we bclicve all Albortau9 have a right to know how Sherritt plans to protect our onvironrnent while moving fimdwith a project like this.
Most peoplc have a genuine concern for the environment and would prefix to see technology which supports the use of sustainabk resources not the ~ouof nomewabla rcsams at thc expense ofthe environment and the people.
Wo are very concerned abut Shmitt's Wck redard with respect to due ddigcncc in these mattms. We am sute no one in this province ox country would lib to see another shtim likc Lynn Lake, Manitoba and the 26 million tonnes of toxic waste Shmritt walked a~yh.
I quote from the message Wrn the Premier: "I pledge to do my best to serve the citizen&of this pat province... ." and I also quote hmthe government's list of prides; "cominua progress on thc Water for life strategy and activitiw to protect Alberta's air, water md land"
We depend on ow government agencies like Al,bsrta Environment to protect us, Wo fcel that it is m the people's and the enviroament's best interest for t.project ,not to be allowed to proceed. Plow don't disappoint us.
FMJD. &'MS irn and Ronnie Ha# Terms of Reference - Questions and Points of Concern
2.1 Assessment of Need
- Discussion of the need far the project should include the option of leaving ~griculturdland intact which can be used for sustai.nable magy production such as sitseeds for biodieseI and grain for ethanol. Also, there fdlots and hog bms in tbe Cowties of Beaver and Mhburn which have Integrated Manure UWon Systems which process manure and prodm power being sold into the provincial power grid. (Iron Creek Colony and Highland Feeders). - We question whether Sherritt's project is the correct choice for the use of our land and water resomes,
2.2 Project Components and Development Thing
- This section sboutd include maps showing the geographic area impacted at each stage of the development and also which waterways will bc impacted,
- The TOR water requirements sMdbe amsidered AT THA SAME TIME as the merits of the project. It should be questioned whether approval should be pntcd if there is not sufficient water or if the environmental impactr; are unacceptable.
2.5 EL4 Summary - The potmtiaI impacts on air, land, and water should be specific and should be quantified. - We want reports ad data to be made available to land owners aflbted by the proiect .
3.1.1 Project Components
- Pipelines and water intake facilities specifically should be added to this section as well 99 power transmission lines and sub stations. Where are these ping to be and who will be responsible for tbese?
- 11) To date we havc not been included in any "community input" for project design and development.
- b) What are some altmative tw:holoeJes? 2 - A section should be included identifying the reasons for the vatious technologies chosen and comparing the difference in the impacts of diffkrent potential techologim. For Exsmple: What are the relative merits d thc different types of cooling systems used (e.g. impa& on water volume used, energy used, air impacts - mist or fog creation, the need for cooling ponds). Mere would cooling ponds be located? How would they be reclaimed?
33Product Handling
- Very specific information ads to be given with rcgards to the pmduots that will be stored evm temporarily 00 site For example, if this plant produces hydrogen, how much will, be stored on site at my om time, what will be used for containment, what .protective messures will be used, what is the emergency response plan should a leak or explosion occur. Specific details of quantities, containmen< and emergency procedms for each chemical nced to be addressed,
3.4 Utilities and Trrr~~~sporbtion
- The benefits of using gwup wit(busses) for workers to the fwiIity both during comction and operation should be addressed to lessen tr&c flow. - Will there be oversized land heavy loads in the nsral areas? - Will dangerous goods be transported through rural areas? - b) Is this project going to generate power on site and what will. be the source of this power generation? - i)The plans to minimize impacts should include a stakeholder process to discuss how impacts with the local community may be minimirml. Stakeholders need to be included so that plans meet community requirements.
3.5.1 Water Supply
- The nssesstnent should critically evaluate the relative merits and disadmtages of different sources of supply, hclud'ing m assessment ofcumulative impacts (i, c.)not only the impact of Sherxitt's proposal, but also ofother projects in the area such as the supply for surrounding towns md fanas which &dy usc water from the North Saskatchewan). - Will the withdrawal of these huge volumes of water impact the city of Edmonton? - What are the other potential water sources? - If "grey water" from outlying communities is Kigconsidered for use in this project, studies must be done to determine salinity, pathogens and contaminants. - JE the grey water is delivered by pipeline, what measures will be taken to prevent leaks and spills wbich will contaminate the mund md &ce water? Who will be responsible for maintenance of the line during the opmtion of the projcct and after decommissio~hg? ULI LLI LOU/ If:UL 1 lUUbbLL341
1 -
3.6 Air Emissions
- g) The assessment should state to what degree the air emissions vvill be chinhirfid". Since many ofthese emissions are deadly men in smdl quantities. what can, be done to eliminate these efuissions? Arc thm recovery processes for tbew emissions? - * There needs to be a specific emergency response plans developed to address air emissions emergencies.
3.6.1 Greenhouse Gas Emissions
- We would require a detailcd evaluation of how Sherritt would obtain a carbon neutral facility. Intensity targets are not satisfictory as the level of greenhouse gwses in the atmosphere may continue to increase with an increase in indudat activity even if tbe intensjty figure impveg.
- Does carbon capture mean motha pipeline is needed? If so the route should be specified. Since C02 is heavier than air, the route should avoid low lying areas.
3.7 Hydrocarbon, ChemZcal, and Waste Mmagement
- * 0 We do not believe them should be on-site landfills as the nearby town of Ryley AT3 has a landfill faciUty including the Clean Harbors Facility for hazardous wastes, Any on-site facility increases the risk of ground water and soil contamination. Would proposed landfills be lcfl &er reciamation? - How does Sherritt propose to handle the malerials fro any yard sites that wiwili be in the PDA and must bc demolished? Also, w-hat e done with buried refuse from old farmsteads? 3,8 Environrnen&l Management Syatems and Contingency pf am - The emergency response plans should be absolutely sp ific to evqpossible aspect of tbe operation, - b) The word 6'miuimize"is too vaguc. DetaiIed plans ot exact figures and limits should be specified.
4,1 Assessment Scenarios
- Stakeholders ndto have access to the data used to the Baseline Case, the Appli~ati~nCase and the (kmulative Effects copies of the cases themselves.
4,4 Cnmrllative Enviranmental EffecQ
4 - This infomation needs to be made available to 4.5 EM Study Area
- How big are thc local, and regional study am? - The Study Area needs to include 3eaverliill. Jake as Amisk Creek drains there. - The Study Area must also include all the areas the will be affected by any impacts on the groundwater which moves through the coal seams. Areas must be looked at south to the Battle River Area by Cmrose, also west and towards the Vegreville area as well as my area9 mereast The pr~posedStudy Arca shown to stakeholders at this point in time is not at all comprehensive enough for a project this size,
4.6 Climate and fir Qualm - The word "mitigated" is too vw. To what levels will these emissions be "mitigated"?
4.8 Land Use, Water Use and Reclamation
- e) How does Sheritt propose to compact: the sub soil to pte-disturbnncc levels? (Without proper compaction it will be impossible to construct stable roaQ or buildings in the PDA as setthg ~411continue to occur indefinitely). - Is recIamation goi% to bc carried during winter months? If so, large bzen masses of soil will 9nelt'' in the spring and facilitate the fonnation of sink holes.
- Will land be available to the stake holders or public for acquisition after reclamation or is Sherritt going to retain ownership of thew large tracts of land?
- c) Many parts of the PDA have a "hard pan" layer just beneath thc sub soil, If' this layer is destroyed, machinery will sink deep into the soil making mobility impossible. What is going to be done to preserve this layex? - What specific processes arc going to be uscd to prevent admixing of thc distinct soil layers? - What methods are going to be used to replace sub soil and then top soil? - What is going to be done with large rocks that will be inevitably brought to the wficc? - How will compaction of the topsoil be prevented? What typc of equipment will be used to prevent compaction? - There are concentrations of salts in the sub soils. Am these stilts going to be brought to the siuface during reclamation and subsequmtly impair the topsoil's abiIity to produce good growth? WLI LLI LUU I IL. UL I I oUOOLLa*I I
- Wow will vegetation be restored? - How will rare and native plant species be restored? - What are the plans to rcstore tree species both deciduous and conifemus that am native to the ad - What are the plms to replace shelter belts planted by stake holders? - How will vegetation in the wet: lands ?xrestored?
4.9.4 Wildlife
: How ate wildlife levels going to be brought back to pre-disturbance levels and prc-distutbance diversity? -. How are the changes in water levels (surface, wetlands and poundwatcr) going to &ect wildlife habitat and migratoxy birds?
4.10 Surface Water and Groundwater
4.10.1 Surface Water
- As previously mentioned the Study Area needs to be larger and more com~hensiveto properly evaluate impacts on wetIands, wildlife, and migratory birds and also the people in the surrounding ares. IC - h) How is the withdrawal of water hmthe North Saskatchewan River going to sffect other users of the water even outside the Study h?(Edmonton, etc,)
* - Is a comprehensive study going to be done to evaluate tbjs project's impact on the water resources of this province?
4.10.2 Grouadwnter Qualie and Quantity
* - g) The inventory of groundwater users must not be limit4 to those in the "Project Arcs" and must include all those whose water comes through the cod seams and also those whose water is supplicd from any sources in the Study Area however far their property is from the "Project Area". - How will damage to the aquifkr layers be repaired to pre-disturbance conditions7 - What are the impacts of dewatering the minc site on grclundwatcr flows at EACH stage of thc project and how will &esc impact Beaverhill Lake and Amisk Crcek and any other natural drainage amis? - 1) What is the density of the monitor wells going to be? (units per am?} G The baseline data must be made available to the landowners. 5. Environmental Effccts Monltorirtg
- An Independent body should bc Mvedin the monitoring for a balanced and objective analysis of the monitoring program's effectiveness and also to ensure regulations w followed, emergency mpnse plms implemented and remediation is put into effect immediately when contamination is discovered,
6. Public Health and Safety - a) The inmeof new people to the atea because of the project increases the risk to the community from a pandemic elsewhere. What plans will be implemented to prevent the possibility of this occurting? - With a project this size there is a possibility of a terrorist attack. Does Sberritt's emergency response plan make provision for this possibility? - h) Is there a plan to prevent high volumes oftraffic at times when ml school buss= are picking up or dropping off students? Will provisions be made for mad maintenance and repair and trnffic direction when oversized, heavy loads and dangerous goods bccomc part of the local traMic? - k) What are the "existing agreements" with municipalities or industry groups? - We as taxpayers have no kformation on my existing agrmcnts. 7. Bistorical Resources.
- The propod Study Areit takes in several vmy old communities. What provision is bein8 made to pmwe old family hs?
- What ptovisions are being made to preserve without disturbance the graveyards such as Bardo Cemetery and Salem Mennonite Church Cemetery both of whlch have been inexistence since the early 1800's? - What provisions I~vebecn made to praave without disturbance the rural Sdem Mennonite Church?
8. Socio-ecolaomic Factors
- a) the number of people who will be displaced dm needs to be stated. i) when will these people be notified? ii) what compensation will they be given for the loss of livelihood? iii) what compensation will be paid for the land, homes, out build-, wells, dugouts, fcnces, utilities and any other improvcmcsnts on the land? iv) will compensation be given for relocation costs for homes, farms businesses at replacement cost levels?
- A comprehensive study needs to be donc investigating the m~tivcimpacts on the study arm: i) transient workers ii) lack of housing iii) inc~easedcrime iv) loss of customers for providers of agricul.tura1 products and servjces. V) loss of custorn~?~~for othm businesses and services as project workers may not reside in area,
9. Public Consultsttion Requirements
- To date Sherritt has becn very vague about all q~tsof thc project Specific information needs to be &t~)to the stakeholders .
Appendix
Water Supply, Water Management and Wastewater Management
- me technical information should include monitoring plans. - b) What is the expected time frame for the storage of waste water streams? Will waste water be stored on this site after the plant is decommissioned?
Conservation and Reclamation Plan
V) Are thwetlands going to be replanted?
* - We believe a group of local land owners should work in conjunction with Sberritt to ensure that the land is reclaimed to its pro-disturbed state or as Sherritt representatives have said have said Werthan it was before", - What is the time hmefor compktion of the! reclamation7 - What is the amount of the bond that will be required to make sum that the reclamation is completed on heand to the satisfaction of local landowners and government standards?
Groundwater
- What will be the density of the monitor wells in the am? Will, it be adquatc ia order to obtain early detection ofany contamination? 8 1 UL/ LLI LUU I If;WL lBUbbLL3ql HUKI LUNbIKULIlUN
Note: We also wish to know how Shexritt dl,deal with any existing and abandoned oil and natural gas weUs that are in the PDA? At the public meeting on Jan. 15,2007 in Round Hill, whcn questioned on this Sherritt's tepresentatives replid ".,.that's not our problem". Ts that a correct statement? Who is responsible? February 23,2007
L- - -L Aberta Enwrcnmgnt Director, Environment Assessment, Central Region Northern Region - Edmonton Alberta Environment 11 1, Twin Atria Building 4999 - 98 Avenue, Edmonton, Alberta, T6b 2x3
F;:: T;!.r 2 A- - " .---- - i To whom it may concern:
RE: Sherritt's Proposed Open Pit Coal Mine and Coal Gasification Plant - Rvlev, Alberta
I would like to express my concern regarding the proposed coal mine and coal gasification plant near Ryley, Alberta. I have several questions that remain unanswered and would appreciate any clarification that you can offer.
My concerns relate directly to the environmental effects of the mine, since the historical impact of such mines on the environment have not been positive and clean up efforts have not proven successful.
In an effort to receive clarification I would like to address three separate areas.
Air Quality:
What kind of assurance do we have of maintaining air quality with a risk of increased emissions? What efforts will be put in place for dust control?
Water Quality:
With industry there is always a risk of harmful chemicals leeching into the water. What is the possibility of selenium, mercury or other harmful substances affecting the water supply, fish and plant life? If such an event were to occur what is the rehabilitation plan?
What will the water source be? At the moment it sounds like maybe a pipeline fiom the North Saskatchewan River, but what other options/sources are being considered?
How long would such a pipeline be and what effect might it have on wildlife/wetlands?
What kind of effects would new roads, pipelines and railway have on wildlife and wetlands?
Beaverhill Lake: What kind of impact will the close proximity of the mine have on the largest lake and bird sanctuary in the region?
This is one of only a few federally recognized Bird Sanctuaries in Canada. Re tremendous natural resource of Beaverhill Lake is the thousands of migrating waterfowl and nesting shore and songbirds are a thrill for residents and visitors alike. Two hundredfifty species have been sighted during migration, while about one hayof that number nest and make their summer home in the area. @tp://www.tofieldalberta. ca/nattrre. htm)
Beaverhill Lake is part of FYHSRN, a wluntary collaboration of private and government organizations, which gives international recognition to rn-tical shorebird habitats and promotes co-operative management andprotection. It is also a Rarnsar site, which is an international body devoted to protecting wetlands. (http://www.mb. ec-gc.ca~nature/whp/whsrn/dfOIsOI. en. html)
Countless birds will be affected by such industry including the endangered Piping Plover. What assurances will be given to keep the lake protected and uncontaminated?
What effects would the mine have on migratory patternshirthldeath rates?
The lake is already shallow and prone to seasonal drought how will water levels be affected by dewatering?
These questions represent only a small part of the concerns we face with such a large-scale project. This area has a rich farm history and contains people that are devoted to preserving the land as well as the history of the area. With the Oil Sands in Northern Alberta devastating the forests, land, water and wildlife I urge serious reflection on the harmful environmental impact of relatively short-term industry.
I thank you for your time, consideration and response.
Sincerely,
9/&A- Caley H am Melanie Daneluk
From: marlene hearn [[email protected]] Sent: Sunday, February 25, 2007 7:24 PM To: [email protected] Subject: Comments on Dodds-Round Hill Gasification Project
February 25, 2007
Director, Environmental Assessment, Central Region Alberta Environment 111, Twin Atria Building 4999- 98 Avenue, Edmonton, Alberta T6B 2X3
Dear Director; Re- Dodds- Round Hill Goal Gasification Project
As a landowner in the Round Hill area, I am very concerned about the impact of this Coal Gasification Project. Following are my concerns: Drain the aquifers and thus affect the Battle River and the communities and farmers near the Battle River the cone of depression due to dewatering can spread over at least 20 km from the mine pit. Groundwater and surface water will be affected not just in the designated area but also to the farmers and hamlets in the 80- kilometre radius surrounding the designated area. potential health effects to the neighbors of the gasification plant such as allergies loss of natural habitat for the wildlife and birds proposed usage of water from the North Saskatchewan River- will the river sustain all the industries’ and cities’ use?? Insist that an Instream Flow Needs assessment be done to include existing and proposed usage of water and the cumulative effect By products of the gasification are sulphur and other impurities- what will be done with these??? Loss of prime agricultural land- reclamation to GRASS and HAY Affect migratory patterns of endangered waterfowl for Beaverhill Lake habitat of the ducks and other birds in the Ducks Unlimited land affect water in the Lake Demay and Dusty Lake, Have impact on Miquelon Lake, Cooking Lake Driedmeat Lake and Bittern Lake
Waste water from the gasification plant- what will be done it
11/6/2009 with it??
The Dodds- Round Hill area has prime agricultural land. Agricultural land is not renewable. Let Sherritt find an area for the location of this plant where farming will not be affected. These are my concerns that I trust will be addressed prior to any progress of the coal mine by Sherritt International.
Thank you for keeping a clean and green environment for our present and future generations. Our natural resources should not be extracted for export to the Americans but left for our future generations to use and enjoy!!!
Yours truly,
M. Hearn
the restaurants participating in Winterlicious 2007
11/6/2009 Melanie Daneluk
From: marlene hearn [[email protected]] Sent: Monday, February 26, 2007 8:58 PM To: [email protected] Cc: [email protected] Subject: Comments by Feb 28 Attachments: feb24,2007.doc
I sent 2- 1 by e-mail - made slight changes and signed M Hearn and then mailed one in- signed Marlene Hearn
Let me know if the attachment comes OK [email protected]
Mortgage rates as low as 4.625% - Refinance $150,000 loan for $579 a month. Intro*Terms
11/6/2009 101 Humberstone Road Edmonton, Alberta T5A 4E4 February 24, 2007
Director, Environmental Assessment, Central Region Alberta Environment 111, Twin Atria Building 4999- 98 Avenue, Edmonton, Alberta T6B 2X3
Dear Director; Re- Dodds- Round Hill Goal Gasification Project
As a landowner in the Round Hill area, I am very concerned about the impact of this Coal Gasification Project. Following are my concerns: Loss of prime agricultural land- reclamation will not be to the original cereal crops of wheat, barley and canola but to GRASS and HAY Beaverhill Lake is located just outside this area and the proposed coal mine will affect the migratory patterns of endangered waterfowl Ducks Unlimited has land within this area and the proposed coal mine will affect the habitat of the ducks and other birds affect water in the small lakes in the area such as Lake Demay and Dusty Lake, Have impact on lakes outside the proposed area such as Miquelon Lake, Cooking Lake Driedmeat Lake and Bittern Lake Drain the aquifers and thus affect the Battle River and the communities and farmers near the Battle River loss of water in the numerous creeks and sloughs in the immediate and surrounding areas the cone of depression due to dewatering can spread over 20 km from the mine pit. Groundwater and surface water will be affected not just in the designated area but also to the farmers and hamlets in the 60- kilometre radius surrounding the designated area. Quality of air will be affected potential health effects to the neighbors of the gasification plant such as asthma loss of natural habitat for the wildlife and birds proposed usage of water from the North Saskatchewan River will be equivalent to the water used by a city – can the North Saskatchewan River continue to be used by industries in the Fort Saskatchewan area and this coal plant without thought given to the overall present and future use of the river??? Thee North Saskatchewan also provides water for other cities such as Saskatoon and North Battleford- how will these cities be affected in the future years ?? Insist that an Instream Flow Needs assessment be done to include existing and proposed usage of water and the cumulative effect By products of the gasification are sulphur and other impurities- what will be done with these??? Waste water from the gasification plant- what will be done it with it?? Within this area are 3 graveyards- What will be done with the remains of our ancestors??
These are my concerns that I trust will be addressed prior to further and any progress of the coal mine by Sherritt International. With today’s technology – is there not a way of getting energy without destroying this prime agricultural land? How about wind or solar energy???
Thank you for keeping our environment clean and green for our present and future generations. Our natural resources should not be extracted for export to the Americans but left for our future generations to use!!!
Yours truly,
Marlene Hearn
Melanie Daneluk
From: Sunny Meadows [[email protected]] Sent: Tuesday, February 27, 2007 5:55 PM To: [email protected] Subject: [SPAM-low] Fw: Dodds Roundhill CG Project
----- Original Message ----- From: Sunny Meadows To: [email protected] Sent: Tuesday, February 27, 2007 5:25 PM Subject: Dodds Roundhill CG Project
Dear Director of the Environmental Assessment Re: the Dodds Roundhill Proj.:
We write to you to express our protest and our concerns regarding the Sherritt -Dodds Roundhill Coal Gassification Strip Mine and Coal Gassification Proposal . Our farm, Sunny Meadows, is within the boundaries of this project. We are heartbroken and horrified to learn that we may be forced to leave our beloved land and community to make way for a Strip Mine. The personal losses and stress should this occur are too weighty and numerous to discuss. As people deeply concerned about the environment, agriculture and the rural community, we must express our opposition to this proposal. This is an area of very good soil for farming. Good soil in Alberta gets gobbled up daily by urban sprawl and other developments. Protecting agricultural land should be a top proirity for Alberta. We ask everyone there to think about just where their food comes from ,please, when it's meal break time at your meetings. Take a moment to consider the soil, the water, the climate and the people who work hard to produce it and the rural communites in which they live. We believe it is worth protecting. We are very worried about the water demands that this proposal requires.The water needs for a project of this scope seem higher than the area can bear. The long term consequences of water loss and damage to aquifers are too great a risk for any economic advantages some may gain from a proposal such as this. This area is recovering from the drought. The famous Beaverhill Lake is shrinking from lack of water. That alone should be an alarm to say no to any project that consumes such high volumes of water. We also worry about the air quality . The coal gassification is supposed to be cleaner. Cleaner than conventional coal processes, yes, but is it really clean enough? Also, what happens if, heaven forbid, there is a fire at one of the proposed plants? Or at the proposed mines? Or leaks in the proposed pipelines? What about increased traffic ? Where does the wildlife go as the land is stripped for mining? This area is blessed with wildlife. This area is part of a well established migratory route for birds. What happens as the land goes to the proposed strip mine and before any reclamation is finished? What about all the trees that take years to grow? We worry about the cemeteries in the boundaries of the proposal. What happens there? Coal, even the so called cleaner methods of burning coal, is the way of the past. It goes against all current thought of reducing global warming. All the energy, resources and time spent by Sherritt or any other company that needs to prove its point that the environmental impact of the proposal would be minimal, would be better spent developing renewable resources of energy and leave
11/6/2009 the coal in the ground and in past history. We thank you for your time and your consideration of protecting this area's environment, the air,the water, the soil, the wildlife, the trees, the grass and plants and this community. Thank you. Sincerely, Julie and Toyosaburo Ishida Sunny Meadows RR 1 Tofield, AB T0B 4J0 Phone: 780-662-3328 email: [email protected]
11/6/2009 Melanie Daneluk
From: John and Catherine Jensen [[email protected]] Sent: Thursday, March 01, 2007 12:00 AM To: [email protected] Cc: Honourable Ed Stelmach (PC); MLA David Eggen (NDP); David W. Schindler PhD Subject: [SPAM-low] Dodds Roundhill EIA
Dodds-Roundhill Coal Gasification Project Environmental Impact Assessment Proposed Terms of Reference
February 28, 2007
John and Catherine Jensen Box 254 Ryley AB T0B 4A0 Telephone/Fax: 663-3680
Director, Environmental Assessment, Central Region Alberta Environment 111, Twin Atria Building, 4999 – 98th Avenue Edmonton, Alberta T6B 2X3 Fax: (780) 427-9102 E-mail: [email protected]
RE: Dodds-Roundhill Coal Gasification Project Environmental Impact Assessment Proposed Terms of Reference
Our comments and concerns with regards to the Sherritt documents are as follows:
We are Beaver County rate payers who believe we will be directly affected by this proposal, should it proceed, as the proposed study area is immediately adjacent to our farm, the home quarter of which is located on NW35-49-17- W4thM. From this point onward, whether this project ultimately goes ahead or not, it will have serious impacts on the planning and decisions we make with regards to our farm. In preparing this submission we are very disappointed that the poster materials on public display at the open houses in Round Hill and Ryley were not made available on the Sherritt website as had been promised to us on two occasions. It is also very difficult to comment and identify specific concerns on a project that the proponent can provide very little detail about. We do, however, acknowledge that we are all at the very beginning of the entire process. Our comments at this time will be very broad and general in nature.
Sherritt’s project documents speak almost exclusively about the coal mine and gasification aspects but only very briefly mentions the “utilities plant” that will be used to produce steam and potentially electric power. The EIA should include complete data and information for this component of the project, both as an individual unit and also as a combined impact/cumulative effect with the mine and gasification units as well. Because the project is already identified to possibly grow in size to four gasification units, this initial EIA should address the complete size. Otherwise all the information will end up being piece-mealed together over time and it will be very difficult for everyone, including the regulators, to obtain a true picture up front as to what the total ramifications of this project will really be. Mention is made of stock piling some coal in the event a “break in coal mining occur”. We did not notice any mention of whether or not a cooling pond or water storage pond will be needed or constructed. How will the plant function in the event there is a water supply/pumping problem? The EIA should address this in detail if a pond is contemplated.
The unnamed intermittent creek that flows through much of our property has its headwaters within the proposed study
11/6/2009 area. There are several tributaries of varying size feeding this creek. What will be the impact of these projects be on this creek and our water rights? We hold several water licences and will continue to require this water for many aspects of our operation. We run cattle and are currently licensed to irrigate crop land, so the quantity and quality of water flowing to our farm is a major concern, especially in years of drought like the ones we experienced here from 2000 to 2002. Although we are not certified organic, we attempt to farm using natural, sustainable, and environmentally friendly practices. What impact would these proposals have on organic and other farming operations and the safety of food production? We would not want to jeopardize the ability of either ourselves or subsequent owners to obtain organic certification. The EIA should address such concerns.
We are very concerned that the North Saskatchewan River has been identified as the major water source for this project. It is our understanding that it is unlikely that the glaciers feeding this river will even be in existence for the 40 year life of this project. We are also told 85% of Alberta’s water is located north of the North Saskatchewan River basin and that this is home to only 15% of our population and industry/water users. This means that 85% of our population and industry/water users are presently tied to only 15% of Alberta’s water supply. Does it seem prudent then to now add a new, and such a large scale and long term water consumer, to the North Saskatchewan River? A large area surrounding the Capital Region of Alberta now receives its domestic water from Edmonton’s water treatment plants. This includes many municipalities, acreages, industry, agriculture etc. The EIA should address this issue, as well as how priorities for the river water would be established should water shortages occur in years to come. Also, “Considering the Saskatchewan River system provides most of Alberta’s water demand; will there be adequate flow of water left over for Saskatchewan and Manitoba; given only 15% of Alberta’s water flows eastward into Saskatchewan?” (http://www.keewatin.ca/Pages/Albertas/water/res.html, accessed 2007/02/21) Also, in discussion of the Saskatchewan River Basin, Saskatchewan Eco Network states, “Almost 70 percent of water consumed in the province originates in the South and North Saskatchewan and Qu’Appelle river systems.”(http://econet.sk.ca/issues/water/basin.html, accessed 2007/02/18)
According to Sherritt’s own website information, there are large scale coal deposits located farther north and west in the Province. The EIA should identify and discuss other alternative locations for such a project that have been considered, and be able to document that moving forward with this particular project at this time is truly in the greater public need and interest? From an overall perspective, would it not seem more reasonable, less disruptive, and less of an impact on so many people in this highly productive agriculture area, if this entire project were relocated farther north? That would also result in the project being outside the North Saskatchewan River basin altogether and in a more northerly river system, one which does not drain into Saskatchewan. The recent years of drought should have provided enough evidence that in extended periods of poor crop yields or otherwise adverse conditions, Canada could have difficulty feeding our growing population. Should not food and water for our population have priority over industrial development that is proposed more for the benefit of the United States than it is for us? The United States has more coal than anywhere else in the world. They could utilize this same coal gasification process on a large scale and look after their own energy needs; they don’t necessarily have to have our oil. Canada is a more northerly country than the USA and we need to have heat in the winter in order to survive. Perhaps we should save some of our energy resources for ourselves so that future generations have what they need to survive. If we run out of food or energy in the future we cannot rely on the United States to share their resources with us. The recent tragedies of 9ll and New Orleans have shown that the United States is either unwilling or unable to help even their own citizens in times of need and crisis.
Do we truly understand the combined local and far reaching effects on the surface, subsurface and/or groundwater of this entire proposed combined project, both during and after the life of this project? How will it ultimately affect the long term future in this area, even in such simple things as local ground water recharge, presence, size and quality of subsequent aquifers, or if they will even exist? Are there water flow maps for the Dodds/Roundhill study area that provide information on the ground/surface water? It is our understanding that there is very little base line data or research available in this entire region. In fact, it would appear from reviewing the Alberta Environment document “Water for Life: Alberta’s Strategy for Sustainability, which is the Government of Alberta’s response to develop a new water management approach and outline specific strategies and actions to address these issues.” (www.waterforlife.gov.ab.ca, accessed 2007/02/18) that allowing this project to move ahead at this time is in fact putting the cart before the horse - it appears the watershed management plan for the North Saskatchewan River is only scheduled to commence in 2007 . For this reason the EIA should address this in great detail. We also have to question who has been involved in planning, assessing and reviewing this project to date. The EIA should document all relevant sources that have been accessed. We would like to have it as a requirement that the EIA include a review and
11/6/2009 commentary section written by various scientific academics, such as water ecologist Dr. David Schindler from the University of Alberta. With more than one world renowned expert living and working in Alberta, we feel it would be remiss and unacceptable to not utilize their combined knowledge and expertise and have their opinions and recommendations made public and given sincere consideration. Their unbiased opinions, given both up front and ongoing throughout the approval process, would tend to add public confidence to the entire process.
We are concerned about all the potential pollution concerns regarding this proposal. This includes surface and ground water, as well as air pollution and the reality of things such as acid rain. The EIA document refers to emissions of PM2.5. A recent University of Washington medical study has found that increased levels of airborne particles, even smaller than 2.5 microns, increased the risk of cardiovascular disease and death. The EIA should require testing below 2.5 microns. The EIA should identify the specifics of what monitoring of water and air will be required and done on Sherritt’s land, as well as on that of surrounding landowners.
With strip mines generally being regarded as “disasters”, we have grave concerns about the land reclamation aspect. The EIA should extensively document the specifics of past strip coal mine land reclamation activity in Alberta so that the public have a true picture of what has actually occurred and how effective it has been. It should not be enough to merely outline how effective and successful it can theoretically be. Once the target of the project has been recovered, in this case the coal, what real incentive is there for the company to “expend” a lot of their financial profits and effort on doing a timely and good job of reclaiming the land. We have heard of many problems in this regard with the oil and gas industry in this Province dragging their feet in cleaning up old well sites. We also question whether or not it is realistic to expect all the settling will be finished within the time frame given prior to possible certification. What are the ramifications and proposed solutions should serious problems arise after certification?
The main CN line runs through our farm and last summer CN constructed a new 2 mile long siding running east of Ryley. We would also request that the EIA document all details of any rail facilities that will be required or are contemplated in conjunction with this facility.
The EIA should provide details regarding any and all pipelines associated with this project, together with documentation relating to all potential safety concerns. The issue of responsibility and liability for all components and aspects should be clearly identified. Sherritt should clearly identify whether or not it is willing and able to take ultimate responsibility for all aspects of the project.
These are our primary concerns at this early stage in the review process. As time goes on we will undoubtedly become aware of other issues and trust there will be an opportunity to bring them forward and have them addressed at that time. Please do not hesitate to contact us if you have any questions or concerns. Thank you.
Yours truly,
John and Catherine Jensen cc:
Honourable Ed Stelmach (PC) Fax: (780) 632-6888 Email: [email protected]
David Eggen, MLA (NDP) Fax: (780) 451-2345 Email: [email protected]
Dr. David W. Schindler, PhD Fax: (780) 492-9234 Email: [email protected]
11/6/2009 Melanie Daneluk
From: Kushnerick [[email protected]] Sent: Wednesday, February 28, 2007 7:29 AM To: [email protected] Cc: [email protected] Subject: Sherritt's proposed Dodds-Roundhill Gasification Project
February 27, 2007
Attention : Director, Environmental Assessment, Central Region – Alberta Environment
Regarding : Proposed "Dodds - Roundhill Coal Gasification Project" [Sherritt in partnership with the Ontario Teacher's Pension Plan]
Our family lives within the "Dodds - Roundhill Coal Gasification Project" area and like many others affected by this proposal, I have a number of major concerns. It would take many pages to convey and explain all those concerns but rather than "write a book", I think it would serve both of us better if I briefly listed those concerns.
WATER [surface] .... after suffering through numerous droughts over the years [including major droughts in 2001, 2002] and watching local bodies of water like Beaverhill, Demay and Dusty Lake disappear, it is obvious that we do not have an abundance of surface water and Sherritt's coal gasification project can have a further negative impact on surface water. It is also very important to realize that tampering with a portion of the water shed in one area also impacts people, communities, wildlife and habitat which are hundreds and even thousands of miles away.
WATER [underground] .... coal seams are one of the best sources of quality potable water. Stripping the coal will have a major negative impact on both the quantity and quality of this water source. When the coal is removed, the loss of that source of water is permanent and this will effect not only those who reside within the proposed project boundaries but also all those who are downstream. A reliable source of clean water is a necessity and for many, that water in those coal seams is their source.
WATER [North Saskatchewan River] .... there are already huge demands on the North Saskatchewan River as a source of water for many cities, towns, villages and industry. The coal gasification project which Sherritt is proposing will draw large amounts of water from the North Saskatchewan [Sherritt seems to be confused about how much water they will actually use, so I'm guessing the water usage numbers shown by them to date are very conservative]. However, the real important factor here is that due to the gasification process, most [if not all] of the water removed from the North Saskatchewan is not recoverable and will be lost forever.
AIR EMISSIONS .... This Dodds - Roundhill Gasification Project will produce a considerable number of emissions and one of those will be carbon dioxide. Sherritt's proposal to simply pump the CO2 back into the ground is not proven to be 100% safe and considering the amount of CO2 that the gasification process produces, this project could have a major negative impact on the environment and lends itself to the potential for disaster.
LAND RECLAMATION .... This proposed Dodds - Roundhill Gasification Project mine boundary is very large in size and will encompass 312 sq. kilometers of agricultural land. Despite mans efforts and Sherritt's claim of reclamation - stripping the land bare, removing coal and then reclaiming this land does not return the land to its original state. Reclaimed land will be unstable and complete ground settlement will take countless 11/6/2009 generations. The construction of buildings on unstable land can be very difficult and costly. It will be many decades before houses and other buildings associated with a farm can be rebuilt on reclaimed land.
SOCIAL IMPACT .... there are many 4th and 5th generation farms in the proposed Dodds - Roundhill Gasification Project area. Given the struggles and hardships which farm families living within this area have endured and continue to do so, should be a solid testament to their love of the land. Sherritt's interest in this gasification project is solely profit. On the other hand, my interest in remaining on the farm has nothing to do with money [if it was, I would have been gone long ago]. I am here because I love and respect the land that Sherritt is willing to destroy for profit. Sherritt can sugar coat the effect that the project will have on the environment and community all they want but the truth is, except for the opportunity to make big $$$, Sherritt's has no interest at all in what goes on in this area.
WILDLIFE .... as man continues to destroy natural habitat in the name of progress, greed and profit, all wildlife suffers. This proposed gasification process will strip the land bare, kill many animals who can not run from the destruction and destroy the natural habitat of those animals who do survive. This destruction does have a major negative ecological impact. Sherritt's proposal to do a wildlife survey by using a helicopter to fly over the project area [which according to their own documents should take no more than 4 or 5 hours] is a joke. To conduct a proper wildlife survey would take many months, if not years.
CRIME .... a large project such as this one proposed by Sherritt will attract undesirable people and crime rates will increase considerably in not only the mine area but also the surrounding areas. We do not lock our doors when we leave home or go to bed at night. Will I still be able to leave my doors unlocked if the gasification project is approved - not likely.
I have seen large land stripping operations [Forestburg, Keephills, the tar sands] and I think we are raping enough land for the sake of corporate and government profit. It would be nice if we pulled our head out of our a** long enough to realize that destroying land, water and natural habitat for the sake of $$$ can have a major negative impact for future generations.
Sherritt's [and perhaps the Alberta Government] interest in the Dodds - Roundhill Gasification Project is solely profit and when it comes to the environment, Sherritt's goal will be to meet the minimum standards so that the project can be approved. There are no guarantee's that existing environmental standards are enough and knowing this, is of no comfort to me, my family or many others who will be impacted by this gasification project.
Bob Kushnerick RR # 1 Holden, AB. T0B2C0
ph 780-688-2415 email [email protected]
11/6/2009 Melanie Daneluk
From: Lonnie Lauber [[email protected]] Sent: Tuesday, February 27, 2007 7:59 PM To: [email protected] Subject: Dodd's Roundhill Coal Gasification Project
February 27th, 2007.
Director, Environmental Assessment Central Region Alberta Environment 111, Twin Atria Building, 4999-98 Avenue, Edmonton, AB. T6B 2X3
RE: The Proposed Terms of Reference for the Dodds-Roundhill Coal Gasification Project.
I am writing to express my concerns with respect to the proposed terms of reference for Sherritt International’s Dodds- Roundhill Coal Gasification Project. My concern surrounds the economic value over time of the output of good, productive agricultural land versus the value of the resource that lies beneath it, which in this case is coal. In a province that is resource rich, the temptation is to extract and benefit from as much of that resource as quickly as possible. I believe that this approach is short-sighted.
While oil and gas and agriculture have had a bit of a rocky relationship in the past, the opportunity exists to extract the oil and gas without destroying the quality of the agricultural resource. The same is not true for the extraction of coal. As the world’s supply of fossil fuels diminishes, the need for renewable forms of energy is on the rise, and hence, the importance of maintaining a healthy and productive agricultural land base. Not only will farmers need to feed the world, which is already a challenge, but they will fuel the world of the future as well.
The extraction of coal, unfortunately is intrusive, and will result in the degradation of good agricultural land. I am not convinced that current reclamation technology is good enough to return the land to its original productivity levels over an extended period of time. Remember, the land will be the principal energy source in the future. Can we afford to degrade good agricultural land for the short term gain of the coal that lies beneath it?
I request that the following issues be considered in the environmental impact assessment for this project: 1. A long term analysis (50 -100 years) of output value of agricultural land versus the value of the coal resource beneath it, including an analysis of how many years it will require for the reclaimed land to catch-up in productivity. 2. A comprehensive study of all past reclamation projects in terms of how well the reclaimed land has produced versus what the production in its original state would have been over an extended period of time. 3. An assessment of all of the coal resources available versus the current land use in those areas with priority given to extracting coal from areas of lower agricultural productive value first.
When all of the oil, gas, and coal are gone from the province, what will be the principal resource in the province? I believe that projects of this nature need to be viewed from a long term perspective, and hope that these issues will be addressed as part of the environmental impact assessment of this project.
Sincerely,
Lonnie D. Lauber
11/6/2009 Director Environmental Assessment Central Region Alberta Environment 111 Twin Atria Building 4999-98 Avenue Edmonton Alberta T6B 2X3
RE: Concerns Over Sherritt’s Proposed Coal Gasification Plant and Coal Mine
I am writing this letter regarding the proposed Roundhill-Dodds Coal Gasification Plant to share my fears, distaste and concerns and am hopeful that my voice, along with hundreds of others, are heard and taken seriously.
When I first heard about this project it didn’t seem real or possible that something of this magnitude and with this many potentials for disaster was even being considered. My fears were not only for the people of the proposed site, but those for hundreds of miles around, the wildlife and plant life (both of the proposed site, and again, for hundreds of miles), the soil, the groundwater, the history and the list goes on and on.
I personally know many of the people from the proposed affected area, specifically to the immediate Roundhill area who will be greatly affected if this reckless plan proceeds. The destruction and disturbance of the land and community directly affects my future. I find it extremely upsetting and unfair that there are literally hundreds of people who may be forced to give up their homes, land, lifestyle, history, heritage, community, family and neighbors, basically life, as they know it. And for what, access to a temporary source of natural resource. Sherritt has invaded these people’s lives, installing a sense of doom and inevitability. These people have developed and lived peaceful quite lives, doing what they love. Some dedicate their lives to living off the land, producing for hundreds and thousands of other people. They have chosen this lifestyle, not always the easiest, but it is what they know and love. Even people’s lives in the surrounding area are at risk of a rude awakening as the noise, pollution, increased activity and population (which is almost always followed by an increase in crime) and a direct change in their surroundings will occur. The people of the area are simply told they will get fair market price for their land. This alone leaves question after question: Who determines this price? Are some people to be compensated more than others? What about people in the surrounding area who are indirectly affected? How can you put a price on one’s heritage, years of dedication, family history and memories, people’s piece of mind and emotional toil, the price of having life long neighbors, a caring community, the price of relocating, future generations altered plans, and simply a price on the irreversible damage that will occur to the land and environment.
This brings me to my next group of concerns. How can a company claim that they will safely tear up such a large area of land disturbing the natural ecosystem on so many levels and be able to reclaim it? Possibly the question goes to the level of reclamation that will be attempted or that is required. It does not take an expert to know that there is no way that Sherritt can or will fully reclaim the area. My first concern with this specific area of the project lies with the absolutely inadequate suggested time for an environmental impact study. One to two years to do an impact study on an area this large wouldn’t even begin to give the necessary resources to fully understand and plan the preservation of the area. Not only the massive directly proposed area, studies should be done on surrounding areas including the proposed pipeline path. On undisturbed land there are hundreds and thousands of different grasses, flowers, shrubs, trees, all different kinds of plants. Along with the plants there are the natural bacteria, fungus, and other microscopic elements. Then you have the endless variety of insects. Stepping up on the scale you have the mammals, large and small, and the countless birds. Every one of these things will be affected, many being wiped out. On smaller scale reclaimed areas there is reclamation with a few grass and plant seeds, a mere portion of what naturally occurs on that land. With these small areas over the course of years more plant, insect and other life will slowly move back onto the disturbed area but it may never return to the original state. Keep in mind I am referring to maybe an acre or two; Sherritt proposes a site of hundreds of square kilometers. For the land (still just talking about the surface) to return to a more biodiverse landscape on an area this large will likely take complete generations. In an area this large land will be un- reclaimed for years, and it takes years for the reclamation to begin, leaving room for other concerns such as contamination, erosion, volunteer resistant weeds and plants and periods of lost wildlife activity. How can they reclaim, or even start to reclaim if they have gathered insufficient knowledge of not only what lies on the land but the intricate relationship that all of these aspects share with one another. The delicate ecosystems are always changing and adapting with natural disturbances. Some plant, animal, bacterial (any form of life) are present some years if conditions are favorable, and dormant or temporarily relocated other years if conditions are not favorable. With this I ask how do you even know what has made this land it’s home for a few years or hundreds of years by doing a study with such a narrow scope and with this lack of knowledge how can you promise to protect and replenish such a wonderful ecosystem.
On a deeper level you have the subsurface soils and ground water. Over hundreds and millions of years our land has been formed. Layer upon layer of history, each layer with unique characteristics. Dependant on external circumstances the soils are always changing and have been since the beginning of time. If you dig a small hole you do not just see topsoil, a clay blend and then clay. Each subsurface is composed of countless layers and there are also the intersecting plains. Glaciers have packed some layers so tightly they act as water barriers; others are light organic material that allows water absorption, filtration and the locomotion for insects, animals and microscopic life. Like the most intricate of systems all of these variables give us our functioning land. It acts as filters and highways for our water, fuel, protection and nourishment for living creatures and plants, and it acts as a timeline, a record of our past. In a reclaimed area this will never be replaced, which gives direct concern to all things dependant and co-existent with the natural land.
Not only plant and animals will be affected but something that is becoming more and more of a concern and an ever rising focus as a natural resource- our water. This should not be taken lightly as this project has the potential to damage and even erase some extremely important sources of water. People of the proposed site and surrounding areas get their water largely from naturally occurring subsurface waters. Even if Sherritt was to “reclaim” the land it is most likely that these naturally occurring water systems would be so damaged and depleted that if people were to move back to the area alternative water sources would have to be installed. These ground waters also connect with other ground waters, meaning that surrounding area would also be affected. How can you take away such a large part of one area and ecosystem and expect it not to directly affect the areas around it? There have been records stating that the coal seams carry on deeper all the way to the Battle River. Does this not raise question and concerns about the effects that could be present all the way along the coal seams to the Battle River and everything downstream from the Battle River? With a closer look it is obvious the huge area that will be at a risk if this project is allowed to proceed. It has just turned from hundreds of people to thousands of people, and to such a vast area that it would be absolutely reckless to allow such a risk and disaster the chance to manifest.
All of the points I have raised are on different possibilities and inevitabilities of just the processes and their affects of the proposed Sherritt mine and plant. All of these concerns are directly on the disruption of how things currently are; this hasn’t even touched on the potential for devastating disaster as a result of mishap. I am referring to things that are a common part of industry. Perhaps a chemical truck is in an accident, a pipe bursts or has a leak, or a problem occurs with understudied injection of carbon dioxide, there are so many potential disasters waiting to happen.
I have made it my clear opinion that the risks and devastation far out weigh the short-term economic gain. How in good conscience can this project be allowed to proceed? To do so would be a direct attack to the people who make up the area, people who dedicate their lives to giving to the economy through their different ways of life. People whom only want to be able to continue with their peaceful lives. It would also be an irreversible assault on our environment, one that we may realize after it is too late and the damage has been done. We live in a beautiful country and province, one that is being tore apart more and more every day. How far will we go before we have erased all of our history and are left with a wasteland?
Sincerely,
Holly MacGougan Melanie Daneluk
From: Dave Maruszeczka [[email protected]] Sent: Tuesday, February 27, 2007 12:20 PM To: [email protected] Cc: [email protected]; [email protected] Subject: Comments on proposed terms of reference EIA - Sherritt Dodds-Roundhill Gasification Project
February 27, 2007
To: Director – Environmental Assessment, Central Region – Alberta Environment.
As one of the residents and land owners within the proposed Sherritt Dodds-Roundhill Coal Gasification Project, I have huge concerns over the impact that this project will have on groundwater, air quality, surface erosion and wildlife habitat. I did not find any indication of the length of time that the parameters of the EIA specifically would be examined or monitored over, prior to the application submitted for approval. To ensure that an adequate view of these critical EIA parts is seen, I would insist on an examination of these parameters for at least a one year period prior to any approval, on a fairly continuous basis. This would provide a complete seasonal baseline for all the variations in the parameters prior to start of work, instead of one shot examinations occasionally.
On the issue of groundwater, an independent contractor should be studying and identifying/mapping the underground/ground water flow locations to depths at least below the expected excavation levels of coal/ground material. While existing water well history provides some indication of these underground rivers/flows (directions, extent, amounts), they do not provide enough of a mapping because of the scattered large area versus depth variations used. One possible method not even considered is the use of reputable “water witching” contractors, to identify the potential of these streams/flows/areas/depths that they cover. These could be substantiated with selective sample drilling where there was no well history to support the results or existing records. It is vitally important to adequately identify these, not only in the study area but in the surrounding regions, to determine the magnitude of the impact and more importantly, how their disturbance can be adequately mitigated. Once these are disturbed, there is no going back.
For air quality issues to be fully addressed, it is vital that again at least a one year history of air monitoring be accumulated (minimum of one station outside each of the 4 direction boundaries of the study area) to capture the seasonal baseline variations for future comparison. This will also set the baseline for future migration/particulate issues of air quality from possible soil wind erosion of exposed piles.
Surface soil erosion of exposed piles (both by wind & runoff) is also seen as a big factor, given the recent years historic lack of sufficient snow cover/rainfall moisture in parts of the study area. Winter wind soil erosion (drifting) of exposed areas without sufficient snow pack occurs in places without covering humus. As there will be no tree/shrub cover in first few years, this becomes a reality to adjacent areas in particular wind directions. An aggressive plan would need to be identified to address this issue.
Wildlife habitat will see dramatic change in the study area, namely it will cease to exist in active working areas (the area that is exposed until some form of adequate cover exists). Two of the big factors to baseline this are methods of determining the extent/population of the study area wildlife and the length of time observations are done. Unless the observation periods are extensive and very periodic in nature i.e week periods in various areas over the course of a year, again for the seasonal changes and migration of wildlife, the extent of wildlife baseline populations will never be seen. One method of getting over this is to actively solicit wildlife information from all the current residents in the study area for their observations of this and
11/6/2009 seasonal changes. As they see the areas constantly and number and types of wildlife/birds/insects in it, a very accurate picture of this is readily obtainable. This obviously could be spot verified by outside observations and examination/data.
Although I have other concerns over the proposed project, the above make up the major environmental concerns that I have. Only a complete environmental baseline measurement assessment as described above will allow a realistic mitigation/solution to be arrived at in reducing the impact such an immense project will have on the area, its people, and surrounding regions.
Thank you for considering these issues and it is hoped that this will provide some basis to help minimize the large impact this project will have on the environment around us.
Dave Maruszeczka
48430 – RR 171 Box 191 Ryley, AB T0B 4A0
Tel/fax: 780-688-2464
cc. Roundhill Protective Association Sherritt
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11/6/2009 PAGE 02/03
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- - --a - = -I- WQU~&EKe-to--t&lllk that as we WmWhis-ebm--- -- gadkathn plant we seoPld if aayttrsiag error ea 4be side of the caution. There are s number of area's that I would like studied md X wonM Eke access to information that has been gathered. It is very im-t twwe ~lokisfmed 4kxhim after we evaluate the available data over a period of time.
The thoughtof sub-par hn& recfrmrnation is disquieting to me. 1: kaue.lived all my MeOR this fama &kt than a few dsysc Other
\-a projects have led to mix reviews some of the land is reputedly less good, some marginally better. Land in the proposed area is some of the best m the pdm.The-land I live on inclndw sail- that bas never bsee broke In the spriag the area is rick with crocuses, between the cars. This could never be reclaimed. Tears well up in my eyes as I think of how this proposed .------devolvmmt ml!mwmdHm dm r'andsm-j. 1.rn cencdthat es we rapidly &xi& to undo GODS wark We are heading for a precipice. We meed to take some deep breaths and look at how and if we do this.
The quiet country side stibess will now be stmebtha- wad ofiadustria?eqaipment it the propose development gea~ ahead, we need to think if we wish to be exposed to this for the next half century. Will the sounds themselves not magnifies the fdngof distress that the propose time of brings. Bow e change win the sound affects affect the matting of thp hawks on mp- F'rtS* X had a university student tell methat this was in her opinion the highest concentration of birds she has ever scene. I can't see them &king ammrd to wait for the end of the noise situatien ef the propesed pmjeclt,
-- _. - .. . . Can this province rally justle a continued addiction to iedealizati- verses &v&piag alternate energy searta9 soch as solar, wind or some other sustainable source of energy.
On the subject ofwater there are many smsofmi The decstkm and amm~tat water &a%# Reeds arc alarming to say the least. We have water to spare, do we have water to spare in 20 years. T?remtmc dtuatfon beally is already at fairly critical levels. As we dig and disturbed aqaa Ar, what affwt will that have now. and in the long term. These effects may be long tern and far reaching, and resemble ripples in there effect. Water is not a guaranteed resources. Do we have the right to tamper with mawthing that may have eR8cts kusdreds of miles away through water depit%6n; StiiiESS-bithis suwect need to be done and the information need to be shad, water contsminetion is another sres of concern. Contminmeat sights are wet to hawaa err* an8 Pets ef ge&
The increase potlntion levels may have an dfccIts that mag not be know for anether geeeratiom. Respiratory dements at increased levels are not beyond possibility. AENV PAGE 03/U3
Are we in the name of questiomaMe shortteargame, mwtgadag am faiase.
3311s shrrittbeen sobjet to s'tberalenvlronknental h~4grtioaof is eaviwent menu1legacy. new there is reputedly a todc waste sight of 21.6 million tons left behind in Lion lake Manitoba that shonld be investigated. laelosing I hope lor more (ime to ask no& cnvironrneatsl qeestiees ef great iiccwm*
S~cerelyyours
Ymcr fellow Caaadiaa aed an cwwreed a
Clayton L. Maurer '70... *.)k.?, . i 4 Fa.7 . W-~CeY..fl.,.. I , ., ...... ,, ......
Melanie Daneluk
From: Cody Nahirniak [[email protected]] Sent: Wednesday, February 28, 2007 8:24 AM To: [email protected] Cc: [email protected] Subject: Response to the Proposed Terms of Reference for Sherritt's Dodds-Round Hill Coal Gasification project Attachments: Response to Terms of Reference Letter_cn.pdf
To whom it may concern,
Attached please find my Response to the Terms of Reference for the Dodds-Round Hill Coal Gasification Project.
Thank you for this opportunity to respond to the document and to express my concerns.
Sincerely,
Cody
______Rangeland Conservation Service Ltd. | Cody Nahirniak : Environmental Planner, Range Ecologist | #3, 8 East Lake Way N.E., Airdrie, Alberta T4A 2J3 | | Telephone: (403) 912-3940 | Cell: (403) 860-4012 | Fax: (403) 948-3148 |Email: [email protected] | www.rcsltd.ca | ______
11/6/2009 Cody Nahirniak Box 56 Round Hill, Alberta T0B 3Z0 [email protected]
February 27, 2007
Director, Environmental Assessment, Central Region Alberta Environment 111, Twin Atria Building 4999-98 Avenue Edmonton, Alberta, T6B 2X3
Re: Response to Terms of Reference for the Environmental Impact Assessment Report for Dodds- Roundhill Coal Gasification Project
Dear Director,
I am writing this letter as a response to Sherritts’s Terms of Reference (TOR) for the Environmental Impact Assessment Report for the Dodds – Roundhill Gasification Project (Dodds-Round Hill project) in order to express my concerns and opinions in regards to this project.
I grew up on a farm just east of Round Hill on the edge of the study area proposed for this gasification project. Along with one of my brothers, I have recently begun farming myself, making us the third generation to farm our land and the fourth generation of Nahirniak to farm in the Round Hill area. I am also a graduate of the University of Alberta, currently working as an environmental consultant with Rangeland Conservation Service Ltd. in Airdrie. Interestingly enough I was also part of the group of consultants who prepared the Environmental Impact Assessment for the Luscar Bow City Project. The combination of these factors means that Sherritt’s proposed Dodds-Round Hill project will affect me both personally and professionally and as a result I will be including my concerns from both stand points in this letter.
The first concern I have with the Dodds-Round Hill project is one that often comes to my mind, although admittedly it may not seem significant to all people. In naming this project Sherritt has spelled Round Hill wrong. Officially Sherritt has named the project the Dodds-Roundhill Coal Gasification Project, making Roundhill one word instead of two. As a member of the Round Hill community, I take pride in that name. It identifies me and where my roots are. By spelling the name wrong I feel that Sherritt has immediately demonstrated that showing respect for the people in the community is not one of their priorities during this project.
My second concern I have with Sherritt’s Proposed Terms of Reference is its general vagueness. From my own experience, and talking to family members and neighbours I have found that the TOR has actually raised more questions and concerns than it provides answers. While I understand that the TOR was created in order to outline the scope of the project and that the study itself may change forms during its progression, I feel that Sherritt has fallen short in considering the concerns of the communities affected and explaining this process to the people. The problem is that the TOR is itself not self-explanatory, nor do I feel that Sherritt has put much effort into explaining the TOR to the people. I would suggest an additional appendix or document attached to the TOR that explains the Environmental Impact Assessment (EIA) process be included as an educational tool for the stakeholders. This would allow people to learn about the process and would encourage them to participate more in the process. Another addition I would like to see to the TOR is some description of what level of scrutiny, and to what standards/guidelines the various studies (vegetation, wildlife, groundwater, and especially Socio- economic, etc.) will conform to. Will Sherritt be allowed to meet minimum requirements or will the high population density and large amount of private land involved with the Dodds-Round Hill project translate into newer, stricter rules? It is my understanding that the Luscar Bow City project had the as yet strictest and most specific TOR requirements of any large scale project in Alberta. In comparison to the Dodds- Round Hill project, Bow City was much smaller and affected fewer stakeholders directly. As a result I would hope that standards for this EIA will be even higher and will be spelled out in such a way that the general public can understand. Having said all this I would like to point out that the Terms of Reference as it currently exists, does cover a wide range of topics and issues and does provide a good starting point for planning of the Environmental Impact Assessment field work.
It is my opinion that the current Terms of Reference for the Environmental Impact Assessment of the Dodds-Roundhill Gasification Project as presented by Sherritt is not yet adequate to satisfy all concerns that stakeholders, such as myself, have about this project. By revising the Terms of Reference to reduce the amount of generalizations used in the Terms of Reference and to better explain the entire Environmental Impact Assessment process and more specifically outlining the study guidelines, I believe that the quality and effectiveness of the document will be greatly improved.
Sincerely,
Cody Nahirniak, B.Sc.
Melanie Daneluk
From: Harvey and Marj Nahirniak [[email protected]] Sent: Friday, February 23, 2007 10:08 PM To: [email protected] Subject: [SPAM-low] Dodds-Roundhill Coal Gasification Project
Attachments: Concerns Related to the Proposed Dodds.doc
Concerns ated to the Propo
This submission contains our respones to the above noted project. A hard copy will follow. Thank you. MN
______Find out the restaurants participating in Winterlicious http://local.live.com/default.aspx?v=2&cp=43.658648~-79.383962&style=r&lvl=15&tilt=-90&dir=0&alt=-1000 &scene=3702663&cid=7ABE80D1746919B4!1329 From January 26 to February 8, 2007
1 Concerns Related to the Proposed Terms of Reference for the Environmental Impact Assessment Report of the Dodds-Roundhill Gasification Project
INTRODUCTION
There are a number of issues that we believe need to be addressed before the Dodds- Roundhill Gasification Project is given permission to progress to the next stage of development. At a time when environmental issues and resource sustainability are receiving widespread attention we must not forget that this project will also have long lasting, far reaching and perhaps devastating effects not only for the people that will be displaced or relocated as result of this project but also for the people that will continue to live beyond the boundaries of the project area.
My husband and I own land within the study area defined by Sherritt but we also have land that is bisected by the study area’s border and some land that lies beyond the border but within several miles of the project area. We presently live on the home quarter where my husband was raised and where we have raised our three sons. I have always anticipated that I would be able to watch my grandchildren play in the same fields and enjoy the same freedoms that my sons enjoyed as children. Recent graduates or soon to be graduates from the University of Alberta, our children have been actively involved in our farm operation all of their lives. This past year two of the boys rented land and began their own farm operation. We had never imagined that there might not be a home place for the third and fourth generations of our family to return to their roots.
One of our greatest joys is that many of my husband’s nieces and nephews look forward to returning to the farm for visits. They are returning to their rural roots as they relive childhood experiences from when they visited their grandparent’s farm. Their children in turn are learning to appreciate life on the farm. These children are the fourth generation of this family that are privileged to share in the uniqueness of the rural lifestyle.
I realize that those comments may not seem relevant to the environmental impact study. However I think it is important to remember that people as well as the environment will be impacted by this project. It is paramount that all concerns are considered before this project is allowed to move forward.
My husband has lived through the turmoil that accompanied Calgary Power’s attempt to mine out this area thirty years ago. He remembers that families and communities were torn apart by conflicting interests and he believes that some of the wounds resulting from those conflicts have never been healed. That is one of the reasons that we appreciate the opportunity to respond to this document and we hope that we will truly be active participants in the process as we dialogue not only with Sherritt, but with the government bodies that regulate their activities. Open and honest ongoing dialogue will hopefully help all of us avoid the conflicts that arose in the 1970s.
REPSONE TO THE PROPOSED E.I.A. REPORT
There are numerous questions and concerns that my husband and I have after reading this document. Neither of us come from a scientific background so what may seem obvious to the authors of this document will require a further explanation before we feel that we understand what is meant. The concerns and questions that we raise will follow the pages in the document and where possible we will identify the item and pages numbers for easier cross-referencing. Having said that, there are a few general comments that I wish to begin with.
I think that it is necessary to discuss the manner in which this project has been approached. People do not fear an event that they understand as much as they fear the unknown. Sherritt International has created fear in the affected communities because they are claiming so many unknowns. They don’t know where the plant will be. They don’t know how they will take over the land. They don’t know what the effects of mining will have on the ground water supply. They don’t know what they will pay for the land that they require. They don’t know how much water will be required for the project. They don’t know ….and the list goes on.
They do know that concerned citizens will have to respond to their public disclosure document by February 28, 2007. They do know that “despite that fact that you do not want to hear this, mineral rights trump surface rights” (Member of the Presentation Team, Public Meeting January 15,2007). They do know that they want to have ongoing dialogue with “any public participant or stakeholder who has a sincere interest in the Project” (Dodds-Roundhill Coal Gasification Project Public Disclosure Document. January 2007 p.18). Although they are now into the second quarter of the project’s schedule as they outlined it on page 15 of the disclosure document, they have not made contact individually with each of the families who live within the boundaries of the project. How do they know if these people have a sincere interest in the project? What do they consider “sincere interest” in the project? Had every landowner and stakeholder received a letter stating the intentions of the company and invited them to their first open house in the late fall, Sherritt would have shown that they truly did want to be start a dialogue with the people who will be affected by this project.
1. In the introductory paragraph it states that environmental and socio-economic effects of the project will be examined in the report. While there is a great deal written about how and what will be covered in the environmental component, the socio-economic aspects of the study are not clearly defined within the document. 2. 1.2 b makes reference to “residual effects” related to other industrial operations. Have they then identified all the other expected and potential industrial operations so that we may have a more complete idea of the extent of the project? 3. 1.2 c ii they talk about “assisting” in monitoring environmental protection measures but do they identify who will be responsible for addressing and covering the costs of dealing with adverse impacts? 4. 1.3 Should the stakeholders not already be informed about what the planned public consultation program involves? They talk about members of the public “who may be affected”. What are the criteria for deciding, “who may be affected”? To date I would suggest that the program for public consultation has not been sufficient and I don’t believe that they have identified everyone who may be affected. Since they do not have a clear understanding of the potential harm mining will have on the ground water supply they do not realize that those affected could live in excess of 40 miles from the project site. 5. 1.4 Will an independent body identify the “issues raised” and are the responses to your department considered part of the public consultation process? How will we know that Sherritt has indeed addressed all the concerns that people submit? 6. 2. The proponent’s perspective of socio-economic issues will no doubt be different from those of the stakeholders. Since Sherritt must have experience dealing with socio-economic issues at the locations of their other projects could they not provide us with a list of what those issues are so that we can respond from our perspective? Never having experienced a project such as this in our lives how can we begin to know the extent of the socio-economic impacts that might affect us either positively or negatively? 7. 2.1 Will the public be allowed to review and comment on the “alternatives” to this project? At this point, when you consider that we were told by one of the Sherritt representatives at the meeting of January 15,2007 that mineral rights override surface rights that would suggest that they are not contemplating any alternatives because they believe that they don’t need to. 8. 2.1 c Will we be allowed input on contingency plans that they may proposed before they are implemented? 9. 2.2 One of the most important considerations for the people affected by this project is the compensation plan. It is difficult to believe that Sherritt would have brought their project to this stage without knowing if they plan to buy or rent the land and what price they consider offering in order to gain access to the land that they require. The proposed project schedule indicates that they will have their application in by the end of 2007 and will start procurement immediately even though the review and permits won’t be completely issued before the first quarter or 2009. That leaves the people in a limbo state. Do they expand their farming operations? Do they sell out now at depressed market prices? Do they wait anxiously for the next year or two and have more stress added to their lives than they presently experience? It seems unfair that we must live in uncertainty for the next 12 to 36 or more months. 10. 2.4 From our perspective it would be helpful to have a map that specifically identifies the local and regional study areas as well as denotes where the structures will be placed. 11. I find it disconcerting that Sherritt is only offering to provide information about their project description and management plans that is “sufficient” for assessment purposes. It gives the impression that they may be in possession of additional information that may or may not reflect favourably on their project. Because we are not knowledgeable about the operation of such a project we would not know what questions to ask. There is an old tale about horse traders. They never lie but unless you ask the right questions they won’t offer any additional information either. Buyer beware! We should not be put into a position where we fail to acquire all the information we need in order to make an informed decision because we don’t know the correct questions to ask. 12. 3.1 Will Sherritt be asked to design their facilities, not to minimum government standards but rather to design their facilities to meet the most stringent environmental and safety standards know to man? If the gasification process can be made so environmentally friendly then the expectation should be that the total project be equally friendly for the environment. 13. 3.1.1 e They need not only to describe where the water wells will be located but also provide an explanation of how drawing from those wells will effect other wells in the vicinity but also further afield. When asked about the impact of this proposed project on ground water, Sherritt has not been able to provide adequate answers. I believe that they should have a disinterested party investigate the issues that relate to ground water before the project proceeds. 14. 3.1.1 i Please have Sherritt identify who the cooperative ventures would be undertaken with that might minimize environmental impacts. As an example, an organization such as Ducks Unlimited might prove a willing partner if they reached an agreement whereby Ducks Unlimited had more land returned to them after the reclamation process than they owned before the project started. I only mention that because at the Open House held in Round Hill, one of the representatives from Sherritt said that in one project, Ducks Unlimited gained more land than they owned before this particular project had begun. 15. Why does Sherritt claim that they will use community input for project design and development? In item 3.1.2 c they make reference to the technical, geotechnical, economical, and environmental criteria that will be used in site selection. Those same criteria must be used for the project design and development as well. Since the community as a whole does not have expertise in those areas what exactly is Sherritt claiming? 16. 3.4 c Reference is made to travel routes and traffic flow but they don’t say which routes they will be studying. Who will bear the costs for increased building and repair and ongoing maintenance of the roadways? Will our children be put at risk because of increased traffic flow through communities and along rural school bus routes? Will regular road maintenance be reduces because the municipalities will have to reassign their manpower and equipment to upkeep roads that will be travelled more heavily because of the project? Who will bear the cost of patrolling these roadways with increased traffic and thus the potential for increased violations of the traffic rules and increased risk for accidents. Who will bear the cost of improved emergency services to handle these potential issues? 17. 3.4 e This item talks about sulphur but makes no reference to reporting how other by products, effluents, raw materials and saleable products will be stored or transported. Sherritt should assume responsibility for all environmental issues that arise as the result of third parties who they hire for this project. 18. 3.5 Sherritt should be responsible to hire a neutral party to perform ongoing monitoring of the water supply for safety and quantity purposes. They do not describe what they will do with the water that will flood the pits after the coal seams are disrupted. Will the account for that water and use it in their calculations to offset the estimated 2.4 to 9.5 million cubic metres that they are projecting they will need.? 19. Who will monitor their monitoring of the waste water and who will ensure that contaminants contained in it will not be released to the environment? Who will ensure that waste water that contains contaminants after treatment and is recycled or re-used in operations such as dust suppression do not contain products which have cumulative affects (eg mercury)? 20. 3.6 It is my understanding that an air-monitoring device has been set up on land that is not in the pathway of the prevailing winds. If the company does not know where there plant is going to be located, as is their claim, how do they know where to place the monitoring devices? If the devices are not in line with the prevailing winds then how accurate are their results? How many devices are they required touse for their study and who determines where they are placed? Shouldn’t they be placed on every site where there is a residence in order to get an accurate picture of air quality? 21. 3.6 g The document lists some of the air emissions but will they be required to list them all? 22. 3.6 h Since Canada does not have the best reputation for stringent environmental guidelines then Sherritt should be required to meet the highest standards in the world for particulate matter. This would be in line with an earlier comment that this should be the most environmentally friendly project within mankind’s ability. 23. 3.10 we need to know who the regional stakeholders are that the document refers to in this section. Sherritt should be ultimately responsible for addressing all issues related to this project including environmental, health, and socio-economic concerns. This item in the document suggests that Sherritt will be involved in these areas but will not be accountable. They need to be held accountable or all their claimed community dialogue will be for nought and they will not have a vested interest in the community once the project is up and running and certainly not after they have mined out the area and begin to withdraw. 24. 4.1 Because this project is of such magnitude and an environmental study has never been undertaken that encompasses an area of this size in Canada, the results of this assessment need to be peer reviewed prior to any licences being granted. Secondly, according to the schedule printed in the Public Disclosure document on p15, the EIA is expected to be completed by the end of 2007. This is not an adequate amount of time to obtain accurate result. Wildlife, bird and plant cycles are in constant flux and one year’s results will not give an accurate picture of the life cycles in our communities. Moisture can vary drastically from year to year and within one or two miles of each other. Area residents should be involved in monitoring the movements of wildlife and the migration of birds. They should also be asked to monitor the rainfall in their area to assist in the collection of data that should be pertinent to the EIA. 25. Modelling is reliable only if it is base upon true science and peer reviewed information. Having identified limitations and sources of errors is Sherritt expected to reassess their information and utilize the best scientific information in creating their models? 26. 4.4 and 4.5 It is surprising that the boundaries of the study are not well defined and commonly known at this time. How can a study of this magnitude allow for “assumptions” when there has been no previous experience to base these assumptions on? 27. Pages 11 to 17 deal with issues and concerns that cannot be adequately studied and monitored in the short time that Sherritt has allocated to this process. They have said that there has never been a project of this size attempted in Canada. Therefore it is prudent that we insist that they devote ample time to do a thorough environmental assessment. 28. 7 How can you mitigate the effects of the project on historical issues? Once the project begins the history is lost for eternity. 29. 8 All the items pertaining to the socio-economic factors deal with economics, employment, services and infrastructure. Where is the humanism in this project? We are not simply a number of people distributed in the area. We are individuals and families. We have names. We have a history. We have ties to the land, to the communities and to one another. If we wanted to be employed we would be. We don’t care if Sherritt uses local, Alberta or Canadian goods. We care if the influx of people increases the crime rate or the pregnancy rate of teenage girls. We care if we have to start locking our church because of vandalism. We care that we love this land that we a tied to by heritage, by marriage, by birth and by choice. Sherritt has given no indication that they care about us at all. 30. Sherritt should be required to negotiate with the stakeholders and landowners as a single group. There should be no “kitchen table” negotiations with individuals or small groups. No one should have been asked to sign agreements for access to their land without everyone being informed about the ramifications of agreeing to that access and without everyone knowing and agreeing to any financial remuneration. Sherritt should promote and encourage the communities to become organized so that they can communicate with one another about the issues and concerns that will arise over the course of the project. Sherritt should identify who they consider meets the criteria for them to consult with. We are into the second if not third quarter of the company’s projected time schedule. We own land in several different areas of the PDA and we have yet to be asked for our input or response to this project. 31. It would be interesting to know how the Public consultation requirements are determined and for whose benefit they are designed. If Sherritt is presently adhering to them in the strictest fashion I would suggest that they are designed to allow for the least amount of contact between the company and the people who are most impacted by this project. I think that is a sad comment on the character of the Sherritt International Corporation.
Conclusion
That completes my comments on the document of the Proposed Terms of Reference for the Environmental Impact Assessment Report on the Dodds-Roundhill Gasification Project. There are a great number of areas that cause us concern and bring questions to mind. At times it appears that Sherritt plans to do due diligence but not go beyond what is minimally required of them. I hope that they are instructed to perform the assessment using best practices not simply meeting baseline requirements. I believe that because this project is of such magnitude and will have far reaching influence on future projects of this nature, the findings must be peer reviewed by an independent body to ensure that all the issues raised throughout this project are addressed in a timely and beneficial manner for all concerned parties.
Thank you for the opportunity to respond to this document on behalf of my husband and myself. We can be reached as follows: Harvey and Marjorie Nahirniak Box 56 Round Hill, Alberta T0B 3Z0 780-672-6664 [email protected]
Respectfully Submitted
Harvey and Marjorie Nahirniak Response to the Public Disclosure Document of the Dodds-Roundhill Coal Gasification Project
Alberta has been blessed with abundant coal deposits and historically that has been an economic advantage to the province. Land owners in the Round Hill area may not consider it a blessing. This is the second time in approximately 30 years that their land, lifestyle, livelihood and heritage has been threatened by a large company who wants to displace them so that the coal reserves beneath their properties can be harvested.
I wasn't part of this community 30 years ago but I do know that that particular conflict has left deep scars within the community and even between family members. Apparently the companies involved at that time came with the intent of displacing everyone they deemed necessary with little thought of how their encroachment would affect the people who lived here. Times and methods have changed and I am grateful that individuals now have the opportunity to respond to the Public Disclosure Document for the proposed Dodds-Roundhill Gasification Project.
My first comment has to be about the name of the project. Many of the people impacted by this proposed project live in and around Round Hill. That name is part of our legacy. When I saw that Sherritt had spelt Round Hill as a single word I considered that a spelling error. I commented about the spelling and was told that the project name came from the original geological mapping that identified the coal seam. That may make sense to someone who is interested in what lies underground. However, we are not a coal seam. We are living beings. I suggest that this lack of sensitivity to the people of the area is an indication of how unconcerned Sherritt is about the individuals they will be negotiating with. From my perspective, it sends out warning bells about how committed they are about having "meaningful" dealings with the people who are affected by this project.
I find the disclosure document vague. I would have thought that with Sherritt's experience in other projects and with the time, money and effort that is necessary to get a plan of this magnitude to this stage of development they would have more information readily available for the public.
P p2 additional infhtructure requirements: no reference is made to where any of these pipelines might run. What other communities besides Round Hill and Dodds will be affected? How do they get a pipeline to Fort Saskatchewan without the need to skirt any of the following, depending on the route they choose: Beaver Lake, Tofield, Sherwood Park. Hay Lakes, Hastings Lake, or New Sarepta? Other obstacles no doubt exist as well. This seems to be an error of omission. 9 p6 what is meant by the plant footprint? What input is required from affected communities and stakeholders in the determination of the final site of the gasification plant? Are these particular stakeholders and communities different than the general public who are affected by this project? Who is being asked to provide this input and on what basis are they chosen? What are the criteria for determining where the plant should be located and isn't that what the company should decide? p8 if additional coal resource delineation drilling is done in 2007 will this mean that additional families/landowners may be affected by the project? Should those people not be made aware of this potential change to the plan so that they can become involved at this consultation stage? p 10 point 9 in the reclamation process states that the land will be returned to acceptable land use as defined in the mines operating licenses. Who determines what is "acceptable"? Will the public have access to that information before the project is allowed to proceed? As an example, if a portion of the reclaimed land that was not previously owned by Ducks Unlimited was turned over to them rather than returned to agricultural use, people might have a different response to the proposal than they would if they believed that the land would be returned to crop production. p 10 while some information is available on the environmental impact of the coal gasification process there is no information provided about the processes of coal transport, preparation and storage. How will the crushing, preliminary processing, washing, drying, etc be accomplished and how will those processes impact the environment? p 11 reference is made to the key feeds to the gasifier but what are the other components? No one can comment on them if they are unknown? p 11 Figure 3 indicates that there will be two sources of rejected material in the coal handling process. What happens to them specifially? p 13 what is the process behind sequestering carbon dioxide in depleted oil and gas fields? Has this been done before? Are there enough depleted fields adjacent to the project or will transporting the gas be a necessity? What are the safety measures involved in the event of an accident during tramportation? What are the long-term effects of sequestering carbon dioxide underground? Have environmental studies been completed on this process? Does it stay contained within the depleted fields or does it dissipate underground? What are the consequences of that, especially for the sub surface water? p 13 what products will be left in the waste water after treatment and then be released into the envirolment? Some literature states that 90% of mercury is extracted during the gasification process. The disclosure document never mentions that mercury is a by-product of coal gasification nor does it spec* how it will handle the 90% or the remaining 10%. p 13 when will Sherritt decide on the type of cooling system they will use? They have made application for water licenses so when will the public be told how much water the project is estimated to require? p 14 how do oxygen plants operate and what are the affects to atmospheric oxygen and air quality? p 14 if third parties are involved in the pipeline idimtmcture are they subject to an Environmental assessment as well? Should those issues not be addressed before the initial licenses are granted? If the plant goes into production then it is unlikely that the pipeline inhstructure will be disallowed because that plant will be in operation and it will need the pipelines. Environmental issues could then be ignored for the benefit of the oil and gas industry. 9 p 15 why does the public have to respond to the proposed schedule so early when the application submission is not due until the end of 2007? Why did Sherritt not announce their project to the public before midway through the fourth quarter of 2006? The timing is another example of Shemtt's insensitivity to the people impacted by this project. Mid November is well into the preparation period for Christmas not the time to be disturbed by the thoughts of being uprooted from your homes and your way of life. The initial open house was poorly advertised and community members had to track down Sherritt officials to confmn that a meeting was actually being planned. Many of the community members learned of the meeting fkom such sources as the people who were hired to cater to the meeting. 9 The next phase is projected to occur in 201 5 to 2020. How does that impact the farnilies/landowners who are going through this disruptive process now and then have to repeat it in 8 years time? 9 Shemtt claims to have significant experience in the operation of refinery facilities, and with mining and reclamation and yet at the open house no one could answer any of our questions about what was planned for this area. Not one of the representatives took notes and when I asked about that, I was told that they would remember the questions! At the end of the evening I did submit a number of concerns in writing and I have yet to be contacted. Unfortunately I do not have a copy of the concerns that I raised. 9 There is no indication of how the Socio-Economic impact will be assessed. What are the requirements and needs of government regulatory review agencies relating to the social impact of this project? Who is conducting this assessment? What are the measurement tools being used in this part of the assessment? What exactly is being assessed? 9 p 18 I find the statement that "Sherritt will engage in ongoing...... with any public participant who has a sincere interest in the project." disconcerting. Will they only dialogue with those who want to see the project proceed? Will they be less willing to dialogue with those who have concerns about the loss of their homes and their lifestyle? Who decides what is "sincere interest"?
That concludes our comments on the disclosure document. It has aroused suspicion and fear by what it did not say as much as by what it did say. There are errors of omission. This suggests that Shemtt can avoid addressing certain issues if they are not mentioned in the disclosure document. As a business that prides itself on its past experiences, Sherritt should have been able to anticipate the extent of information that the local communities who are affected by this project would be looking for. I do not believe that they do not have the interest of the people at heart. I do believe that they will attempt to consult with individuals or small groups of landowners and stakeholders as that will better serve their purpose. If that were not so then why have they not contacted each family individually to begin establishing a workable relationship? Considering the magnitude of this proposed development and the effort that must have been put into it up to this point we would have anticipated that Sherritt would have been able to answer most of the questions posed to them on the night of the open house and that this document would have addressed more of the concerns that are unique to this area. Hopefully permission to proceed to the next step will not be granted until Sherritt addresses the issues that the landowners and stakeholders raise now and in the future.
At the last public meeting we were told that even though we would not be happy to hear it "mineral rights supersede surface rights". The meaning was clear. There is no way that Sherritt will be denied permission to proceed with this project. That would suggest that this whole process of negotiations/consultationsis worthless. I truly hope that this is not so. At this point we believe that no one knows what the fbture holds for us. However it is our responsibility and our privilege to exercise our rights as citizens of this province to ensure that the concerns of the average citizen are not ignored while large companies and the energy sector flourish.
Respectfblly submitted by
Harvey and Marjorie Nahirniak Melanie Daneluk
From: [email protected] Sent: Tuesday, February 27, 2007 11:57 PM To: [email protected] Subject: Letter of Concern
Attachments: letter to AENV.doc
letter to AENV.doc Attached is my letter of concern about Sherritt's proposed Round Hill - Dodds coal gasification plant.
Thank you -Kyle Nahirniak
1 Director Environmental Assessment Central Region Alberta Environment 111 Twin Atria Building 4999-98 Avenue Edmonton Alberta T6B 2X3
Concerns Over Sherritt’s Proposed Coal Gasificiation Plant and Coal Mine
A project of this size carries with it not only significant socio-economic impacts to the local community and surrounding area but it also has the potential for severe, far reaching, and acute, irreversible environmental damage. As a hydrogeologist I recognize that a project of this nature built on such a colossal scale will result in a number of ecological and environmental catastrophes, the question is not if this occurs but when it does and how it will it be dealt with. There are issues of ground water loss and contamination, air pollution, surface water loss and pollution, noise pollution, disruption of migratory birds and animals, and loss of habitat for many species just to name a few. On top of these daunting environmental issues sits the socioeconomic impacts to the local peoples that will be affected by this project. Having been born and raised on the family farm which sits in the proposed mine area I feel that I am impacted by all aspects of this projects foot prints.
I will address the environmental issues first as they are not doubt the easiest to quantify and have the potential to impact the greatest amount of people. Working in the environmental consulting industry I do have some experience with environmental impact assessments (E.I.A.) and as such I have many doubts about the scope, depth and intensity of the proposed E.I.A. as it has been presented by Sherritt’s primary environmental consulting firm (Millenium). The most glaring inadequacy of the proposal is the time frame over which is to be completed. Originally a one-year plan now possibly extended to two years is not enough time to carry out a proper assessment in which seasonal, annual and multi-year variations should be taken into account for every ecological variable. To me this shows that Sherritt is not willing to take the time to do credible baseline testing before they start their project.
Another concern of mine which was down played by Sherritt and Millenium at the last community held meeting in Round Hill was the potential impacts to ground water in areas that are down stream of the mine site. They confessed that the mine would totally eliminate all current ground water sources in the area but seemed uninterested in how that would affect people outside the mine site that use the same aquifers. They also failed to satisfactorily address their plan for replacing ground water for those in the mine and immediate surrounding area.
I have done a little research of my own using published hydrogeological reports for the counties of Camrose and Beaver from the Alberta Geological Survey. It is obvious from these reports that eliminating the aquifers in the proposed mine site will strongly impact ground water resources for a wide area ranging from the mine site all the way down to the Battle River. It then occurred to me that perhaps they were not too concerned with this scenario despite the fact that it would have severe consequences for hundreds of farmers and several communities (Bawlf and Rosalind that use Horseshoe canyon water sources) because they eventually intend on strip mining all the coal between Tofield and the Battle River.
The Battle River itself is also in danger as a result of this project since the prairie fed water body depends entirely on surface runoff and ground water fed springs to keep it flowing. The very coal seams that Sherritt plans to mine are responsible for carrying ground water all the way to the Battle River providing water to it and a majority of farmers and communities along the way. This raises a concern not only for plants and animals that call the Battle River Valley home, but also people downstream on the river that rely on it for domestic, agricultural, industrial, and or aesthetic reasons.
There are also implications for the North Saskatchewan River as Sherritt proposes to pipe water from the river for use in its plant. Nine and one half million cubic meters of water a year could be used by this project, the vast majority of which is unrecoverable. This has implications for wildlife, farmers, and communities downstream that depend on the water in that river. The North Saskatchewan River already suffers from serious removals for industrial, agricultural, and municipal purposes, another serious demand for water would be unsustainable seeing that the rivers main water source, rocky mountain glaciers, are shrinking every year.
Surface water is also a great concern as the entire Amisk creek water shed, which feeds the very fragile and ecologically invaluable Beaver Hill Lake, will be eaten up by the mine. Beaver Hill Lake plays host to numerous migratory and permanent avian residents, it also is vital hub for wildlife in the area. The water levels of the lake are already in jeopardy and eliminating one of its few inputs could be potentially devastating. Wetlands on the proposed site are another ecological resource that will be dearly missed not only as sources of ground water recharge and wildlife sanctuary but also as sources of carbon storage. I think that the potential carbon storage of all the water bodies being destroyed by this project should be considered in the over all carbon production of the plant.
Production of CO2 is another very big concern considering just how much of it is going to be created by this project. Sherritt says that they have a possible market for the concentrated CO2, depleted oil fields and or sequestration in the subsurface. However I think it is important to note that just because they pump the CO2 into the ground doesn’t mean it stays there forever. In the case of increasing oil production there will be CO2 coming to the surface with the oil, what happens to it at this point? Sherritt should still be responsible for this carbon; its release at any point in time should be prohibited not just at the point of its initial production. The affects of CO2 in the subsurface, be it dissolved in water or collected in a hydrocarbon trap may still have unknown effects and these should be more thoroughly investigated before injection is considered as a viable option of carbon sequestration.
The impacts to migratory and year round flora and fauna cannot be taken lightly when an area of over three hundred square kilometers is going to be destroyed. Despite the claim by Sherritt that the affected land will be reclaimed in seven to ten years, it is unlikely that the shrubs, trees, and wetlands that define the ecosystem will be back in full production for at least 25 years if ever again. No doubt some opportunistic species will use the opportunity to move in and take over the “reclaimed” areas however reestablishing the biodiversity of the area to it current state is not something that can be done over half a generation. On a smaller scale the impacts might not be as bad as the displaced species could slowly move back into the area from the near by undisturbed surrounding habitat. However when an area as large as the one proposed is going to be disturbed then the reestablishment of native species will not be an easy prospect. Ecosystems are never easy to reestablish due to their complexity, interconnectedness, and fragility. The ecosystem, however is not the only concern for people living in and around the proposed plant and mine site, they also have concerns about themselves, their families and their future.
The social implications of this proposal are also potentially devastating to local land owners and communities. As for myself I was born and raised on the family farm and I had one day hoped to return to it and raise my own family their as my family has been doing since 1901. The up rooting of hundreds of people whose land will be consumed by this mine is a terrifying prospect that provides a lot of people with sleepless nights. Sherritt assures residents that they will be fairly compensated for their land, which might sound great if someone was looking to sell out and move. The reality, however is that people will be forced from their homes and those unlucky enough to live on the periphery of the mine will not only not get compensated for decreased land value and possible environmental damages. They will also see and hear their serene prairie landscape turned into an industrial jungle. The economic impacts of which will include increased noise, traffic, crime, and decrease in quality of life that always accompanies an unwelcome population boom. The people in this area chose to live there because it presented them with the lifestyle they wanted. The probability that social and economic Benefits will follow the development of this project is as likely as a massive strip mine and huge industrial “factory” positively contributing to biodiversity and environmental well being.
As a community we have united in an attempt to preserve our local community, environment and livelihoods. It is our hope that the governing bodies that represent the public interest recognize the extreme and irreversible environmental and social damages that an industrial project of such excessive scope and scale could create. Perhaps the focus of energy development in this province should shift towards renewable sources instead of continuing to exploit our finite non-renewable reasources at the cost of the environment and our provinces people.
Kyle Nahirniak FROM : TOM NRHIRNIRK PHONE NO. : 7806726021 Feb. 27 2087 82:41PM PI
Round Hill, A1 bmta BOX55, TOB-3x0 February 24,2007 Director, Environmental Assessment Alberta Environment 1 1 1, Twin Atria Buildrng 4999-98 Avenue, Edmonton, AB., T6B-2x3
Dear Sir or Madam, I wish to oppose the application of Shjrritts proposal for the hdds-Round Hill Coal Gasification Project and have concerns regtwdii the use of 1.5 million Imperial gallons of water per day per stage that will be made into hydrogen for the refinery and as a carrier for the movement of the heavy crude from the tar sands which I heard wodd be exported to the USA to their refineries and there would not be any water lefi ir~this Province for use for all us in Alberta, which was not told at any of their meetings with us. In their public disclorn document they do not reveal what will happen to the water aquifers in this amand the surrounding distances that the aquifers will be dewatered. This dewatmhg could effect people fiom 20 to 50 miles mund and when that happas who would be responsible for those peoples water needs. #- Another point is that Sherritt did not discuss the dust and impacts of it on the community and the mowding mininti: area. # Another point is that Sherritt did not discuss how much and how high are the levels of noise and how thcy will control it regarding the impact on thc surrounding community. #- Another point which has not been discussed in details of the mlamation of the different classes of soils and the time heof returning them to equal to or better than before. #- Another point was never discussed on how large of a performance bond would be posted during and after finishing of the project in favor of the c0mmun.i~.A 50 biilion dollar bond is the very minimum and be paid up for 25 years after. #- Alberta hvirronment has to enforce an Emergency Response Plan. #- There was no guarantee for the Salem Mennonite Church and Communiv Center as to what wodd happen to their Church and their Grsveyard. ilf- There was no discussions to the people in this community regarding the Centamid awards to findies that will lose their awards in the next few years. #- There was no discussions or how the communities will be protected from crimes when the project is bdtand &r.
A public Hearing shall be held prior to any licenses granted to Sherritt or Carbon Development Corporation on Water Diversion or Mining operations nad Land r2eclnmatiokls. 2--&..4 Tom Nhnkk, Land owner. FROM : TOM NRHIRNIRK PHONE NO. : ,7806726021 Feb. 27 2007 82:42PM P2
Page 2, letter re Sherritt
c.c- Premier Ed. SteImach, M.L.A. #307- Legislature Building 10800-97* Avenue Edmonton, AB., T5K-2B6 c.c.- Honourable George Groenweld, M.LA. Minister of Apiculture, 408 Legistatwe Building 10800-9?, Avenue, Wonton, AB., T5K-2B6 c.c.- Honourable Me1 Knight, M.L.A. Minister of Emqy, #40Ld Legdature Building 10800-97bh Avenue Edmonton, AB., T5K+2B6 c.c.- Honourable Rob Rmer, h4.L.A. Minister of Environment 323 - Legisl~Building 10800-9pAvenue* Edmonton, AB., TSK-2I36 c.c. - David Eggen, M.L.k 501 Legislature Annex 9718-107 Street. Edmonton, AB., T5K-1E4 February 27,2007
Ms. Dolores Noga 33 Gramridge Drive Sherwood Park, AB T8A 5G4
Director, Environmental Assessment, Central Region Alberta Environment 11 1, Twin Atria Building 4999 - 98 Avenue Edmonton, AB T6B 2x3
Dear Director:
RE: Dodds-Roundhill Coal Gasification Project
I am writing in response to the Public Disclosure Document and the Draft Environmental Impact Assessment Terms of Reference for the proposed Dodds-Roundhill Coal Gasification Project. I am a landowner in the proposed mine-study area. My comments are grouped into four categories.
Public Consultation I first heard about the proposed project while listening to the radio on my way to work. The interview indicated there was a public meeting in Ryley that evening. I attempted to confirm this by checking the Sherritt website and was most surprised to find no reference to a meeting. I attempted to phone some of the numbers in the back of the Public Disclosure Document and failed to receive an answer at any of them. Finally it was the radio station that was able to tell me where the meeting was to be held and at what time. It was not until a week after that meeting that I received a package of information by mail. The package consisted of the Public Disclosure Document, a Public Notice, and a 'To whom it may concern' letter. The Draft Environmental Impact Assessment Terms of Reference was not included and I had to print these off the website. In past approvals for a variety of projects in Alberta, approval officers or relevant Boards have placed a strong emphasis on the conduct of the public consultation program. Initially, the consultation for this project has not been remarkable. As a landowner, I should have been notified in person prior to the meeting, announcements of meetings should be on the Sherritt website, and there should be a general phone number that is answered during office hours. The Documents The documents are based on the assumption that a project of this magnitude will work exactly as the company envisions it and that in 40 years, the land will be successfully returned to what it is. Technically, reclamation is intended to return the land to 'equivalent land capability' which is not the same statement as retunzing the land to what it is now. I am left with a number of questions, some of which are: What replaces the coal? This question is two-fold: in addition to being a layer underground, it also serves as a filter and storehouse for water. The documents make no reference to an emergency response plan. Are there not inherent risks in the gasification process which may require response? Why is Sherritt not actively pursuing alternative renewable sources of energy development? There is no indication of what will be done with the land when the project is finished. There is a promise of jobs being created but no indication of skills required and no commitment to see that local residents are given an opportunity to secure these jobs. Indicating that jobs will be advertised locally is not adequate.
Risks What types and volumes of emissions might the gasification plant generate? The federal government recently announced it would create a $1.5-billion Eco-Trust and Clean Air Fund to reduce pollution and greenhouse gases. Is the gasification plant going to be a major contributor of these? Are there any potential health concerns to living in the vicinity of or downwind fi-om the plant? On the radio interview, a Sherritt representative made the comment that it was 'not their intent' to contaminate anyone's water supply. I anticipate that further studies will indicate what they will do should this happen, not what they intend to do or not do. The project will use vast amounts of water. As well there is the potential that the water table will be disrupted by the mining operation. Is this the best use of available water supplies and who benefits from using the water in this way and who else then does not have access to adequate supplies?
Underlying Assumptions The entire proposal is based on the assumption that the gasification project is a worthwhile endeavor and that because a company has the 'right' to the resource and the capacity to develop it, that the project can progress without much disruption and indeed, that it should proceed. My questions are: Who benefits from this project? While a decision will be made based on 'in the public interest' which is often supplemented by adding 'having regard to social, economic, and environmental effects', the answer to this question is really that it benefits the shareholders of the proponent. In obtaining a copy of the eia terms of reference, I noticed a news release on the Sherritt website "Sherritt Reports Record Earnings in 2006". Who fails to benefit fi-om the proposed project? Included in this group would be local landowners, farmers, the community, and the environment. Even at a preliminary stage, through reviewing the documents, it is obvious that the community will not continue to exist should the project be approved. Too many people will be displaced and while there may be some economic spin-off for local towns and villages, mere numbers of people do not make a community. At a recent meeting of the Provincial - Territorial Ministers responsible for Renewable Fuels in Gatineau, February 2 1,2007, the Ministers committed to competitive programming and tax treatment for renewable fuel development relative to other countries, particularly the United States. They also made a commitment to encourage regional economic development in support of the new industry. An approach that is progressive and environmentally responsible in its thinking, is surely of more value than mining coal with all its surface destruction. The project also assumes that accessing a resource which will have a life-span of 40 years is of worthwhile, whereas continuing to use that land as fannland or allowing it to serve as natural areas with all the benefits that accrue to that, is of less importance.
I realize the project is at a very preliminary stage. Thank you for consideration of my concerns.
Sincerely,
C/Ld ,.did Dolores" 7oga Februaxy 22,2007
Director, Environmental Assessment,Central Region Alberta Environment 11 1 ,Twin Atria Building 4999-98 Am. Edmonton, AB T6B 2x3
To Whom It May Concern:
In regards to the proposed Dodds-Roundhill Coal Gasification Project, I, as . a landowner in this area, have grave concerns about this project.
The following are a few of my concerns:
Environmental - groundwater (quality and quantity, during and after mining) - watershed area that feeds Beaverhill Lake runs through the proposed area - wildlife (you cannot put a dollar value on geese, chickadees, tadpoles and frogs, crocus, ducks in sloughs, owls, hawks, coyotes, deer and moose) - the disruption of native grasses, trees and flowers (the ecology of our land which is adjacent to the Amisk Creek) - the disruption of our good farmland - air and noise pollution associated with mining activities.
Economic - we are making a huge sacrifice while everyone else is seemingly profiting from this project. - we question - - How can it be worth it to us? Social - loss of community - the Bardo community has been active and close-knit since its establishment in 1894. We have land that is still being farmed by descendants of the original homesteaders and if the mine goes through there will be no next generation to carry on the Bardo Community traditions and history. - we choose to live here because we feel safe and protected. Our neighbors care and look out for one another. We will lose this security if we are forced to relocate. Our community is irreplaceable and priceless!! - to keep the history of the Bardo Community alive, our members have put tens of thousands of volunteer hours into fundraising, and upkeep of our community center. - the uncertainty of our future is creating enormous stress on the family unit including the youth in our community. - loss of homes, livelihoods, jobs, and vocations. - the future of the Bardo cemetery, which was established in 1898, is of great concern to family members.
As of today, I am opposed to this project. There are too many questions and concerns that have not been addressed to our satisfaction. We are faced with so many unknowns,our lives are left in limbo.
We see no positive outcomes at this time.
With concern, 7.- 7.- ,,f$!ALd-;;"" Melanie Daneluk
From: Oracheski, Jane [[email protected]] Sent: Tuesday, February 27, 2007 4:56 PM To: [email protected] Cc: [email protected] Subject: Dodds - Roundhill Coal Gasification Project Attachments: Response.doc
Response to Proposed Terms of Reference for the EIA Report
The attached document was prepared by the two members of the Round Hill-Dodds Agricultural Protective Association whose names are attached. The comments reflect concerns recorded at a public meeting of the Association held February 15, 2007 in Round Hill.
Thank you again for the opportunity to respond.
M. Jane Oracheski <
11/6/2009 Round Hill-Dodds Agricultural Protective Association Response to Proposed Terms of Reference for Environmental Impact Assessment Report For Dodd-Roundhill Coal Gasification Project
1. Sherritt showcased their proposed project for the stakeholders of the Study Area in November of 2006 with limited advertising. The Round Hill-Dodds Ag. Protective Assn. invited Sherritt to present a more in depth explanation and answer questions at a Town Hall meeting in January of 2007 prior to their presentation in Ryley. Sherritt used this forum to distribute their Public Disclosure Document. The Proposed Terms of Reference for the EIA document were not distributed as generously. Note: both documents are very similar in appearance and many stakeholders were unaware there were two documents. The Public Notice published the next day directed interested persons to respond in writing to the Terms of Reference not the Public Disclosure Document. Until the RH-DAPA made it generally available at a meeting in February 15, 2007, there was confusion as to which document required a response. The confusion cuts into the time to prepare a response and we hope Sherritt will assure itself in future that their communications are understood.
2. How can Sherritt claim to be able to examine socio-economic effects of their project in the area affected if they choose not to spell the name of the area correctly? Socio means people, not a coal seam. Respect for those affected would indicate more respect for local values are exhibited. If Sherritt were truly interested in the impact of the project on the community they would realize that spelling the name correctly is important to the community.
3. Regarding the scope of the EIA, the technology supporting this project is so new to Canada and the size of the necessary study area so huge, we are not confident that all the issues can possibly be addressed in a single year. Environment changes seasonally and annually. Surely this large an undertaking deserves more than one year to adequately assess results.
4. Regarding the Project need and alternatives considered: at a public presentation on January 15 of 2007, the question was asked, “What if we do not agree to sell or lease our surface rights for the project?” The response from a Sherritt representative was “Mineral rights, trump surface rights.” This response suggests alternatives are not realistically being considered.
5. Regarding Project Components and Development Timing: the EIA is our primary concern at this time and we feel that a project of this scope deserves much more time for development. One of our wishes is that the project successfully passes a peer review before any licensing is considered.
6. The Study Area appears to represent the 312 sq. Km. only. We have had concerns express from as far away as Wainright.
7. Water is the big question. Where is it coming from and how much? We have yet to hear any solid answers on this topic.
8. Product handling: How do we know that all of the issues are addressed. Even if present standards are met, does this assure best practice?
9. Does Sherrit realize that between Ryley REA and Battle River REA, we own all our electrical transmission lines? How do they propose to deal with the fact that many of our buried telephone lines will need to be disrupted? Country roads are not designed for heavy equipment or heavy use. Who will pay for the cost to upgrade and maintain them adequately?
10. We are very concerned about sub contractors providing services to Sherritt who will have access and undefined, as yet, accountability to stakeholders. We need to be very definitely assured that Sherritt will bare the ultimate responsibility for any issues related to their project.
11. Regarding Water issues: we have innumerable concerns and questions for which there have been few adequate answers so far. We anticipate the opportunity to respond to Sherritt concerning these issues when their answers are available and prior to any licensing.
12. Prevailing winds in this area are primarily from the NW and SE depending on the weather systems involved. Will the EIA air monitoring systems take this into account where the effects to all stakeholders are concerned and if so, how?
13. We are concerned that the Study Area is extremely small compared to the Affected Area. Where are the boundaries for the Regional Study Area? What kind of communication has been established with regional participants? Are residents and municipalities between the PDA and the Heartland Industrial area, i.e. Fort Saskatchewan aware of the possible impacts on their environment?
14. We need to know how accurate and reliable the baseline data is that Sherritt relies on regarding environmental conditions. We also need to know if it is being collected from adequate and appropriate sources and locations.
15. Regarding the approximately 5% of the region still covered in native vegetation, there are definite reasons for this aside from the fact that they have little of no agricultural value. Many provide a means of slowing wind erosion of our topsoil. The historic Battleford Trail traverses the study area, and any traces of that trail might be found in those areas. Because they have not been used they are valuable as wildlife habitat. How does Sherritt propose to protect or reclaim such non-renewable; assets?
Thank you for the opportunity to respond. We look forward to hearing more from you as the project progresses.
Marj Nahiniak and Jane Oracheski on behalf of:
Round Hill-Dodds Agricultural Protective Association Rm.#10, Round Hill Fire Hall Round Hill, Alberta T0B 3Z0 B AND C RUDE PAGE 01
Feb 28,2007
Director, Environmental Assessment, Central Region Alberta Environment] 1 1 1, Twin Atria Building 4999-98 Ave Edmonton, AB, T6B 2x3
To Whom It May Concern:
In regards to the proposed Dodds-Roundhill Coal Gasification Project, we have concerns about this project. The following are a few of our concerns:
Environmental: -groundwater (quality and quantity-during construction and mining, after construction and mining, and also for the next 5-100 years)* - watershed (as the proposed area of the project falls within the runoff area for Beaverhill Lake). - watershed (quality and quantity for our dugouts to fill, moisture for our land and crops -and ultimately for our livestock and livelihood). -the disruption of native grasses, trees and plant life. -the disruption of Amisk Creek. -the wildlife (deer, moose, coyote, owls, hawks, ducks etc). -air, ground, noise, and visual pollution associated with construction and mining. -disruption of farmland (unusable during mining and questionable quality of reclaimed land). B AND C RUDE PAGE 02
Economic: -1 am a farmer; the job I have chosen is to farm this land. -if we are forced to relocate, the cost of relocating for our family in the mental, physical, and economic sense,
Social: -loss ofcommunity (we chose this community because of the people, the land, the history, tbe location, the security). -the Bardo community has been active since its establishment in 1894. Many people have land that is still being fanned by descendents of the original homesteaders. What will happen to the next generation? -the history of the Bardo Recreation Association, Bardo Community, and the Bardo Lutheran Church site is important. Community members have put many, many volunteer hours into hdraising and upkeep of these places. -the loss of homes, livelihoods, jobs and vocations. -the future of the Bardo Cemetery, which was established in 1898, is a concern for the family members.
Presently, we are opposed to this project. There are many questions and concerns that have not been addressed. We face many unknowns and uncertainties.
With Concern,
QQWand Christy Rude RR#I Tofield, AB,TOI> 450 Melanie Daneluk
From: Lonnie Lauber [[email protected]] Sent: Tuesday, February 27, 2007 7:51 PM To: [email protected] Subject: Terms of Reference - Dodd's Roundhill Coal Gasification Project
February 27th, 2007.
Director, Environmental Assessment Central Region Alberta Environment 111, Twin Atria Building 4999-98 Avenue, Edmonton, AB. T6B 2X3
RE: The Proposed Terms of Reference for the Dodds-Roundhill Coal Gasification Project.
We are writing to express our concerns with respect to the proposed terms of reference for Sherritt International’s Dodds-Roundhill Coal Gasification Project.
The Salem Mennonite Church and Cemetery are located within the boundaries of the proposed strip mine development. This church has been in existence in the area for 97 years, and during that time the church has been the center for this community. Many of the landowners in the area are members of the Salem Mennonite Church, and will be displaced from their property as a result of this project.
Not only does this project threaten the physical structure of the church and cemetery, but also the membership of the church, as some in the church community will be affected by the project while others will not.
The proposed terms of reference, section 8, is focussed primarily on the economic benefits to the surrounding communities, with little to no emphasis on the social impacts on the potential break-up of our church and community. There should be provisions in the terms of reference to study these impacts. We also have concerns about the social and emotional implications that may result from moving our cemetery.
Our members have expressed their concerns about what this project will potentially do to our church and community. We would appreciate if the initial impact assessments would include provisions for studying the social impacts on the church and community.
Sincerely,
Lonnie D. Lauber Chairman, Board of Elders, Salem Mennonite Church.
11/6/2009 Melanie Daneluk
From: Bill Sears [[email protected]] Sent: Tuesday, February 27, 2007 9:52 PM To: [email protected] Subject: [SPAM-low] re EIA Terms of Referance Dodds-Roundhill Coals Gasification project
To whom it may concern
My hope would be that any Environmental Impact Assessment would take into account the long term environmental impact of strip mining a possible 312 square kilometres of agricultural land in what is commonly known as the Parkland area of the prairies. This is an area of farmland mixed with areas of natural bush, native grassland and significant wetlands. Because of its close proximity to the Edmonton region it is rapidly becoming an area of rural residential development, usually making use of existing or abandoned farm sites. I would hope that by definition an Environmental Impact Assessment would weigh the future value of this area, most specifically it’s native bush, grasslands and wetlands (with a view to how endangered these areas are throughout the province and the world) vs the short term use of the area for energy extraction for an export market. I would hope that as a society we do not loose sight of how important our natural areas will be in the future , not just for a healthy environment but for a healthy humanity.
I would also like to ask how I might have input into the EIA as the process goes foreword.
Thank you
JW (Bill) Sears RR1 Tofield Alberta TOB 4JO Email billsears@telus .net
Phone 780-662-2660
PS I live and farm within the proposed mine area
11/6/2009 02/28/2007- 15:26 URH RETRIL FOOD SUS + 94279182 i
Director, Environmental Assessment, Central Region A1 berta Environment 11 1, Twin Atria Building, 4999-98 Avenue boaton, A1 berta T'Gf: 2x3
Dear Shemtt,
Tbis letter is in response to your "Public Notice -Dodd-Roundhill coal gasification project environmental impact assessment proposed terms of reference". I am deeply opposed to the project and have many public and enviranmental health and safety concerns directly related to this project should it get ~pproval.I believe that it will have a negative irreversible impact on both the community and the environment. There are three main areas of concern that 1have and would like to know how Sherritt intends to address these issues should it get approval for this project.
1- The amount of water needed to run the project. My understanding fiom the literature given by Sherritt is that this project requires a tremendous amount of water in order to be operational. I do not believe that Beaver County has the water table required for a project of this nature. The alternate source of water would have to come from the already stressed North Saskatchewan River. Do we redly want to mess-up temperamental aquifers that affect the IiveIihood of not only the farmers ttylng to make a living but the small towns east and all of the wildlife who exiat in this beautiful productive countryside? 2- Air Quality and land destruction wth all the mining comes dust, grit and emissions. Who will be re\sponaiblcto ensure that the air quality is not reacbing toxic levels? It will without doubt change the quafit-of the air hrn what it is now and not in a beneficial manner. This will force the population of people, livestock and wildlife to breathe contaminated air. Our land will be permeated with the emissions and covered with layers of dust. This will affect the growth quality d suminability of the crops. How will these chemicals affect the organic status of pasture land and gardens where no chemicals are to be used? Who will be monitoring these levels and to what standards are they to be compared to? 3- Time- Ahr reading the literature it seems the project is being rushed, What time hehas been put on this project? How long will the study take? How does Sherritt honestly expect to do a thorough proper study of the land migration and habitat of wildlife, alpiculture, water, population and livestock in one year? It takes longer than that just to establish migrational patterns for the various groups. How about safety of the people who reside in the area. Noise levels, increased ~~c,air pollution, increases volume of people 14sto more crime and activity how will these issues be addressed? Toxic spills, accidents, removal of product and equipment, wear and tear on hiways and gravel roads dl potential hm:rdous 10 ciora; com~~vths wdl msanitw the sde'ry of our comunily? 1t aesyears 15:26 RETQIL 02/28/2007- UQH FOOD SVS + 94279102
to understand environmental patterns and water sustainability how can Sherritt expect to begin a project ofthis grandeur without considering all of these factors.
In conclusion I would like to ask how is it that we are Land ownm and ranchers in this area and Sherritt did not even have the consideration to invite us to an information meeting. I know after talking to Mr.Drinkvvaer that it was posted in a newpaper, not our tovm newspaper but one 40 Km away, flow informative and fair to the community is that? That is certainly not the best way to build a foundation on trust. If this project is going to be such a huge benefit to the community why is Shenit trying to be so discreet about it? I hn't believe that Shefiitt understands the change it will mare to those of us who live here, How are we supposed to plan for our future without knowing whether we will be able to live on our land? Whether our land (if we are able t;o keep ir) wiIl be safe and able to grow crops, pasture or raise livestock. Our past present and fume is being fleeted by a project that has not even been tested in Canada yet. A project that is to prod~icea product synthetic gas .This product Synthetic gas has no buyer yet. It has possibly a third party group who will care even less than Sbefiitt does about our laad our people our lifestyle ow livestock and our wildlife. Boy, does that leave me feeling reassured that it is all for a common good.
I look forward to hearing from your orgauization for some clarification and solid answers with factual information on the concerns above.
780-663-3922 780-289-8945 (daytime) PAGE 03/06
ALBERTA ENVIRONMENT
Regional Sewices February 22,2007 Central Region
.*wr-.%-. --
Directox, Environmental Assessment,Central won Alberta Eh&onment 1 1 1 ,Twin Atria Building 499998 Ave. Edmonton, AB T8B 2x3
To Whom It May Concern;
In regards to the proposed Dodds-Roundhill Cbal Gasification Project, I, as a landowner in this area, have grave concerns about this project.
The foUawing are a few of my concerns: Environmental - groundwater (quality and quantity, during and after mining) -watershed area that feeds BeavexhW Lake runs through the proposed area - wildlife (you cannot put a dollar value on geese, chickadees, tadpoles and frogs, crocus, ducks in doughs, owls, hawks, coyotes, deer and moose) - the disruption of native grasses, trees and flowe;rs (the ecology of ow land which is adjacent to the Amisk Creek) - the disruption of our good farmland - air and noise pollution associated with mining activities. Economic - we are making a huge satdice while everyone else is seemingly profiting ftom this project. - we question - Haw can it be worth it to us? PAGE 06/06
Social - loss of comm* - the Bardo community has &en active and close-knit since its establishm~tin 1894. We have land that is still being farmed by descendants of the original homestead- and if the mine goes through there will be no next gederation to car- on the Bard0 Community traditions and history. - we choose to live here because we feel sde and protected. Our neighbors care and look out for one another. Wewill lose this dtyif we are forced to relocate. Our community is heplaceable and priceless!! - to keep the history of the Bardo Community alitre, our members have put tens ofthousands of valunteer hours into fundraising, and upkeep of our commtinity center. - the untxxtahty of mw hrtarre is creating enormous stress on the family unit including the youth in our community. - loss of homes, lkdihoods, jobs, and vocations. - the future of the Bardo cemeterp, which opag established in 1898, is of great concern to family members.
As of today, I: am opposed to this project. There are tob many questions aqd concam that have not been addressed to our satisfaction. we an faced with so many unknowns, our lbbs are left in lidb,
We see no positive outcomes at this time.
With concern, February 22,2001
Director, Environmental Assessment,Central Region Alberta Environment 11 1 ,Twin Atria Building 4999-98 Ave. Edmonton, AB T6B 2x3
To Whom M May Concern:
In regards to the proposed Dodds-Roundhill Coal Gasification Project, I, as a landowner in this area, have grave concerns about this project.
The following are a few of my concerns:
Environmental - groundwater (quality and quantity, during and after mining) - watershed area that feeds Beaverhill Lake runs through the proposed area - wildlife (you cannot put a dollar value on geese, chickadees, tadpoles and frogs, crocus, ducks in sloughs, owls, hawks, coyotes, deer and moose) - the disruption of native grasses, trees and flowers (the ecology of our land which is adjacent to the Amisk Creek) - the disruption of our good farmland - air and noise pollution associated with mining activities.
Economic - we are making a huge sacrifice while everyone else is seemingly profiting from this project. -we question - - How can it be worth it to us? Social - loss pf community - the Bardo community has been active and close-knit since its establishment in 1894. We have land that is still being farmed by descendants of the original homesteaders and if the mine goes through there will be no next generation to carry on the Bardo Community traditions and higtory. - we choose to live here because we feel safe and protested. Our neighbors care and look out for one another. We will lose this security if we are forced to relocate. Our community is irreplaceable and priceless!! - to keep the history of the Bardo Community alive, our members have put tens of thousands of volunteer hours into fundraising, and upkeep of our community center. - the qnqedainty of our future is creating enormous stress on the family unit including the youth in our community. - loss ~f homes, livelihoods, jobs, and vocations. - the future of the Bardo cemetery, which was established in 1898, is of great concern to family members.
As of today, I am opposed to this project. There are too many questions and concerns that have not been addressed to our satisfaction. We are faced with ST many unknowns, our lives are left in limbo.
We see no positive outcomes at this time.
With concern,
Melanie Daneluk
From: louise [[email protected]] Sent: Wednesday, February 28, 2007 10:46 AM To: [email protected] Subject: Sherritt's Dodds Roundhill Coal Gasification Project Attachments: Letter to Alberta Environment.doc
Director, Environmental Assessment, Central Region
I have attached a copy of our commentson the EIA terms of reference for the above proposed project.
Louise and Larry Strilchuk
11/6/2009 I am responding to Sherritt’s Dodds Roundhill Coal Gasification Project proposed terms of reference for the environmental impact assessment report. I have listed my concerns in the order that they appear in the document with reference to the general topic or to the specific item.
1.3 Public Consultation – Sherritt has done a poor job of informing landowners within the proposed project area of their intentions. They should have sent each of the affected landowners a registered letter stating their intent along with a schedule of meeting dates before they arrived in Round Hill with their open house. In this manner, everyone in the affected area would have been notified and made aware of their plans. This is the procedure Enbridge follows with all landowners to inform them of proposed work on their pipeline, even if the landowners’ property is not directly affected. A lot of the residents were not aware of the project unless they happened to read a notice in the local papers or heard about it from someone else. Not everyone receives or thoroughly reads through them.
2.1 Is this project really needed? Is the company truly concerned about saving the natural gas supply for heating homes or have they discovered a way to turn their coal rights in this area into millions of dollars for themselves and their investors? The need for this project is contingent upon the construction of bitumen processing facilities in the Fort Saskatchewan area, contingent upon the further development of the oilsands in northern Alberta. The development of these projects will put a tremendous strain on the affected communities (social, health, infrastructure, etc.) and the surrounding environment (water, air, and soil). It will cause a large increase in green house gas emissions at a time when we should be reducing these emissions not increasing them. Should we be developing these resources at such a rapid rate when clearly the province will not be able to sustain such growth and development without negatively impacting our environment and our residents?
3.1.1 (c) How will this dewatering and large consumption of local water affect the surrounding landowners’ water supply?
(e) What well source(s) will the plant(s) be using, and how much water will be used?
3.1.2 Sherritt has not yet issued a site development plan to illustrate the location of components (i.e. plant sites 1 and 2, cooling pond, etc.). A mine plan has not yet been disclosed. The general area has been outlined but the starting point and the direction the mine will go have not been made public. In fact, when first introducing this project to the community, they claimed not to know where the actual mine was going to be located. The area being considered was somewhere within the red area on a tiny map they handed out to the public. Sherritt has not identified the location of all on-site storage nor their containment and environmental protection measures. Sherritt has not asked the community if they want this mine and associated plants in their area. They just excitedly informed them of their intentions. Should a company be able to come into an area and set up their plants and mine for coal without the consent of the residents in the community they will affect? Clearly, Sherritt has not used community input for project design and development since they developed their project plans before they presented them to the residents of this community.
3.4 What type of power transmission lines will be required? Where will they be located? What about the negative impact on the health of the residents and their livestock? What about increased rates in leukemia to those residents in close proximity to these high voltage lines.
(b) Where will workers be housed? Will the increased transient population and traffic movement lead to increased crime (i.e. theft) in the area? (i) How will Secondary Highway 834 be affected? If the plan goes ahead, the highway will most likely end 2 miles north of SH 617. How will this impact residents and others that use this highway now to get to Hwy 14 and Tofield? Will travel time increase and will residents along surrounding gravel roads see increased traffic and significant dust problems as commuters travel around this mine area?
3.5.1 Where will they source their water? They suggest a pipeline from the North Saskatchewan River. What about the communities that rely on this same river for their water? Are there any water licences being issued for the North Saskatchewan River? The amount of water they are requesting is equal to the amount of water the City of Lethbridge uses in a year. Does the river system recharge itself at the same rate of depletion? They mention using local water as a supply source. How will this affect the residents and many others outside the mine area that depend upon groundwater that exists within the coal seams that are going to be mined? They may be able to reclaim surface area but once the coal is removed, the water supply will be gone forever. The underground aquifers will be damaged and that damage is irreparable. The mine area is a recharge area for the Battle River. It has been suggested that many communities to the south (Bawlf, Rosalind Kelsey Daysland) and east (Wainwright) will be negatively affected when the aquifers are damaged and the water is gone. How can this project be allowed when the water supply of so many communities is at stake? What will happen to the drinking water supply for the residents within the PDA and surrounding area? Underground aquifers will be destroyed. Where will the residents be able to access a safe reliable water supply after the mine?
3.5.2 (b) What will happen to the lands up and downstream of the mine area when the flow of waterbodies is disrupted? Will sloughs and dugouts that rely on spring runoff and heavy rains to replenish their supply dry up while others overflow and cause flooding of cropland, roads and even residences? The water level in Beaverhill Lake is already low and the level at Miquelon Lake is steadily declining. How will this affect these lakes? One is on a major migration route and nesting area for birds, and the other has just undergone major renovations and scheduled to reopen this summer.
3.5.3 What are the components of the wastewater that will be generated by the mine and plants. How will they affect the ground water in the surrounding area? Some of the byproducts of burning coal are sulphur and mercury. It is a known fact that mercury is a cancer-causing chemical. The chemical makeup of groundwater in other mines in the Battle River area have higher levels of Na and SO and total dissolved solids than in the surrounding unmined coal areas. This will inevitably seep into the surrounding areas and into the water supply.
3.6 What toxic substances this plant will emit? How will they affect the wildlife, residents and livestock? What about the health of the residents that will be living close to the plant site(s)? They state that the CO2 emissions will be safely sequestered in underground caverns. This is not proven, it is speculation. There is lack of proof that burying billions of tonnes of C02 is a safe thing to do. Will it eventually reenter the atmosphere and/or leech into the groundwater?
3.7 How will they store and transport hazardous and dangerous waste products/byproducts to and from the plant site? What if there was a leak or spill, how will the residents be protected?
4.5 The proposed EIA study area should not only include the PDA but a much larger area. Not only will residents, livestock and wildlife within the area be negatively affected but so too will residents in the surrounding area. Where will this study area be and will it be large enough to properly assess the impacts?
4.7.1 We currently enjoy the peace and quiet afforded by living in a rural area. When we step outside, we may hear the sound of birds chirping, cows mooing, or sheep baaing. However, when these plants start operating, our peace and quiet will be gone. With plants operating 24/7 for 40+ years, our tranquil existence will cease.
4.8 Water Use – Sherritt has two options for cooling in their plant. Air-cooling and water-cooling. The 1st option would be more environmentally friendly as it would not require the use of precious water. However, Sherritt has stated that this is not financially feasible because their profit margin would decline substantially therefore the use of water for cooling is the preferred method. Should a company’s bottom line be more important than the environment?
Reclamation – Sherritt proposes to return all mined land to its original condition. It will place overburden at the bottom of the pit and cover with clay and soil. The overburden can and does contain hazardous products. Information to substantiate this statement is available on the following site http://www.metts.com.au/clean-coal-technology.html
“Mine rehabilitation that includes the reduction in carbonaceous material going into overburden and pit reclamation material should be looked as a serious environmental activity and one that has major local and regional environmental consequences. The carbonaceous material contained in overburden can have significant environmental consequences that include, the leaching of sulphuric and sulphurous acid from the overburden, the emission of toxic VOCs that include aromatic compounds from spontaneous combustion in the wastes, the physical destabilization of rehabilitated land through spontaneous combustion coupled with the loss of vegetation and mineral/rock decomposition, and the emission of CO2 from slowly oxidizing coal and organics without the creation of useful energy. One area of coal utilization that could be further 'cleaned-up', and usually does not appear on the Clean Coal Technology horizon, is improved pit and mine rehabilitation. “
4.9.4 Wildlife – Sherritt proposes to spend approximately 5 hours in early March/2007 studying the moose and deer in the PDA. Is this indicative of the time they intend to spend on studying wildlife in the area? Wildlife does not remain within the PDA but roams throughout the region. Their proposed study of wildlife is too short and cannot be undertaken in such a short period of time. A 2-3-year study would provide them with a more thorough understanding of the wildlife resources in the area.
6 Public Health and Safety – How will the health of the residents be affected? The air pollution and groundwater contamination will cause an increase in illnesses and disease. Why should the health of the residents be put at risk for this proposed plant? Will this not increase medical care expenses for the regional health authority and ultimately to the province?
8 Socio-Economic Factors – Sherritt has stated that their project will create jobs for people in the region. When Sherritt came out to meet with the residents they explained their mine process to the residents like they were grade students and not knowledgeable enough to know how a mine would operate. It was ridiculous! Residents within the PDA already have jobs! They are agricultural producers, and many are also employed elsewhere. These jobs will not benefit the affected people. This project is for approximately 40 years. Many of these residents are descendents of the pioneers in this region and have been here for 100+ years. This is their home. It has taken many years and plenty of hard work to build these farms and for Sherritt to suggest that they can reclaim an area to its original condition after they have mined it is absurd! Who is going to put their business and life on hold for 10 years while waiting for Sherritt to reclaim their property? This proposed project has raised a lot of questions and concerns. Should a landowner consider expanding his operation? What will be the environmental consequences of this proposed project? Perhaps he was planning to have his children join his business. Can they, should they consider this choice. It puts a lot of stress on the producers in this area. So many unknowns. What about the land value? If someone wanted to sell out and leave, who would want to buy their land? Once others know about the proposed project, why would they want to buy land in this area knowing they may be bordering a mine pit or large plant and be subjected to air borne toxins and an unreliable, perhaps unsafe, water supply. What happens if the water supply disappears? This applies not only to the residents within the PDA but also to anyone else that relies on the same water source.
There are too many unknowns and uncertainties surrounding this proposed project. I believe it is purely for the financial gain of Sherritt and its associated companies and will create too many environmental problems.
Director, Environmental Assessment,Central Region Alberta Environment 11 1 ,Twin Atria Building 4999-98 A=. Edmonton, AB T6B 2x3
To Whom It May Concern:
In regards to the proposed Dodds-Roundhill Coal Gasification Project, I, as a landowner in this area, have grave concerns about this project.
The following are a few of my concerns:
Environmental - groundwater (quality and quantity, during and after mining) - watershed area that feeds Beaverhill Lake runs through the proposed area - wildlife (you cannot put a dollar value on geese, chickadees, tadpoles and frogs, crocus, ducks in sloughs, owls, hawks, coyotes, deer and moose) - the disruption of native grasses, eesand flowers (the ecolagy of our land which is adjacent to the Amisk Creek) - the disruption of our good farmland - air and noise pollution associated with mining activities.
Economic - we are making a huge sacrifice while everyone else is seemingly profiting from this project. - we question - - How can it be worth it to us? Social - loss of sxmmmay - the Bardo community has been active and close-knit since its establishment in 3894. Wehave land that is still being farmed by descendants of the original homesteaders and if the mine goes through there will be no next genewtion to carry on the Bardo Community traditions and history. - we choose to live here because we feel safe and protected. Our neighbors care and look out for one another. We will lose this security if we are forced to relocate. Our community is irreplaceable and priceless!! - to keep the history of the Bardo Community alive, our members have put tens of thousands of volunteer'hours into fundraising, and upkeep of our community center. - the uncertainty of our htare is creating enormous stress on the family unit including the youth in our community. - loss of homes, livelihoods, jobs, and vocations. - the future of the Bardo cemetery, which was established in 1898, is of great concern to family members.
As of today, I am opposed to this project. There are too many questions and concerns that have not been addressed to our satisfaction. We are faced with so many unknowns, our lives are left in limbo.
Weeee no positive outcomes at this time.
With concern, Director, Environmental Assessment,Central Region Alberta Environment 11 1 ,Twin Atria Building 4999-98 Ave. Edmonton, AB T6B 2x3
To R%om It May Concern:
In regards to the proposed Dodds-Roundhill Coal Gasification Project, I, as a landowner in this area, have grave concerns about this project.
The following are a few of my concerns:
Environmental - groundwater (quality and quantity, during and after mining) - watershed area that feeds Beaverhill Lake runs through the proposed area - wildlife (you cannot put a dollar value on geese, chickadees, tadpoles and frogs, crocus, ducks in sloughs, owls, hawks, coyotes, deer and moose) - the disruption of native grasses, trees and flowers (the ecology of our land which is adjacent to the Amisk Creek) - the disruption of our good farmland - air and noise pollution associated with mining activities.
Economic - we are making a huge sacrifice while everyone else is seemingly profiting from this project. - we question - - How can it be worth it to us? Social - loss of community - the Rado community has been active: and close-knit since its establishment in 1894. We have land that is still being farmed by descendants of the original homesteaders and if the mine goes through there will be no next generation to carry on the Bardo Community traditions and history. - we choose to live here because we feel safe and protected. Our neighbors care and look out for one another. We will lose this security if we are forced to relocate. Our community is irreplaceable and priceless!! - to keep the history of the Bardo Community alive, our members have put tens of thousands of volunteer hours into fundraising, and upkeep of our community center. - the mcert of oar future is creating enormow stress on the family unit including the youth in our commuhity. - loss of homes, livelihoods, jobs, and vocations. - the future of the Bardo cemetery, which was established in 1898, is of great concern to family members.
As of today, I am opposed to this project. There are too many questions and concerns that have not been addressed to our satisfaction. We are faced with so many unknm,dur lives are left in limbo.
We see no positive outcomes at this time.
With concern, VILLAGE OF BAWLF Box 40 Bawlf, Alberta TOB OJO
Phone - (780) 373-3797 [email protected] www. bawlf.com
February 22,2007 ~bertaErnironment tq,,rtnem F3wbn - Edmonton Director, Environmental Assessment, Central Region I Alberta Environment 1 1 1 Twin Atria Building 4999 98 Avenue . I Edmonton, Alberta -s- . .;>. -*.v+-,., . I -4- - T6E 2x3 --. r
Dear Sir:
RE: Dodds-Round Hill Coal Gasification Project
The Village of Bawlf is a growing community of 375 people 24 kilometers east of the City of Camrose. We are blessed with an abundant supply of excellent water 'which is rare in this area. The source of our water is ground water. We are deeply concerned about the potential impact of the Coal Gasification Project at Dodds-Round Hill on our water. Please inform us if we have a need to be worried.
Thanks.
Yours truly,
Myrna Schapansky Municipal Administrator VOEGTLINFAMILY PAGE 01
R.R. 1 Tofield, AB TOB 450
February 19,2007
Director, Environmental Assessment, Central Region Alberta Environment 1 1 1, Twin Atria Building 4999 .- 98 Avenue Edmonton, AB T6R 2x3
Re; Prowsed Do-ll Coal Gasification Project.
Dear Director,
The proposed Dodds-Round Hill Coal Gasification project should not be allowed to proceed for the following reasons: 1. The coal provides a source of water for the wells in the community and removing the coal will disrupt the water supplies for the area. 2. rt is doubtful that the land can be restored to a productive level once it has been strip-mined. The land will likely become very salty when the coal has been removed since there will be nothing to keep the salt below the root level of the plants. 3. The life of the proposed project is only 40 years whereas the productive capacity of the land will continue indefinitely when farmed as it is at present. 4. The area is a major watershed for Beaver Hill Lake which is a major body in the flyway of migratory birds. 4. There are a number of cemeteries in the area which should not be disturbed. 6. It is a poor time for such a project since Alma's economy is already overheated and there is a shortage of labor. 7, It will have an enormous social impact and virtually destroy a stable community. Thank you for giving these concerns your consideration.
Yours trQ, 7 VOEGTLINFAMILY PAGE 01
Lyle Voegtlin RR 1 Tofield, Alberta TOB 4J0
February 16,2007
Director, Environmental Assessment, Central Region Alberta Environment 1 1 1, Twin Atria Building 4999-98 Avenue, Edmonton AB. T6B 2x3
Attention: Director, Environmental Assessment, Central Region
RE; Dodds-Round Hill Coal Gasification Project
Concerns with the proposed project. 1. Soils. a) The public disclosure document incorrectly lists the soil as being mostly Chernozemic when according to the soil survey they are mostly Solonetzic which are much more dificult if not impossible to effectively reclaim. The coal provides the internal drainage which keeps the naturally occurring salts below the rooting zone. A long term study (50-100 years) to prove it can be successfully recla~mcdshould be done. A short term study will not be adequate because it likely will take a wet climatic cycle for the problem to become evident. This study could easily be initiated at the Dodd's Coal Mining Company site.
b) Reclamation is not complete until all ecological function is restored including availability of uncontaminated ground water.
2. Water. a) Surface water in the proposed site is a major part of the watershed that feeds Beaverhill Lake which is an internationally recognized bird sanctuary. Contaminat~oncould have international ramifications, b) Ground water. The study area is a ground water recharge area for the Battle River watershed. Again any contamination or disruption wuld have far reaching effects.
3. Plants and Animals. a) Small pockets of native rough fescue grassland still exist in the area which become increasingly important due to their rarity. These srtts are important germ plasm banks for flora and fauna. Reclamation of native fescue grassland is virtually impossible. VOEGTLINFAMILY PAGE 02
4, Economics. a) Timing. Is this project needed at this time? Alberta currently has a labor shortage and construction costs are very high. The uncontrolled Tar Sands development is causing all kinds of infrastructure problems and this project will likely f'an the flames. The proposed timetable for the project also indicates inadequate study of the issues.
b) Alternatives. Other possibilities should be investigated. Solutions involving conservation and consumption of urban waste should be cofisidered. C) Value of natural ecosystem. According to the Biosphere experiment a natural ecosystem provides societal benefits calculated to be millions of dollars per acre. d) Compensation. How do you adequately compensate someone for the destruction of fifty to 100 year old shelter belts and farm sites? Do previous owners get land turned back to them after reclamation if they so desire?
5. Social. a) Community Stability. This project is relatively short term when considered in terns of the life of a community. The west end of Beaver County is experiencing a rapid expansion of subdwisions and influx of people which already has a destabilizing effect and puts pressure on infrastructure. The proposed mining site is a less transient population which provides stability. Their removal will exacerbate the situation.
These are some of my major concerns. Thank you for your time and consideration.
cc: Round Hilt Dodds Ag Protective Assoc. L. Whillans & S. Whillans March 06,2007 R.R. 1 Tofield Alberta TOB 4J0
Attention: Director, Environmental Assessment, Central Region 11 1, Twin Atria Building 4999-98 Ave Edmonton AB. T6B 2x3
I am very disappointed in the manner in which Sherritt International has been conducting its public consultations. To date, no one has contacted me in person, except to phone about 3 weeks ago. As a result, I misse learning about the public meeting which took place in Ryley and Round Hill. This project affects my property.
I was finally able to get some additional information fiom the local Round Hill fmers group February 16,2007.
I have concerns about the potential harm to surface and ground water sources on my land. This surface water flows into Beaver Hill Lake at present; it appears that Sherritt will be using this water for their purposes, further depriving the lake of adequate water for water fowl. This is a migratory route for ducks and geese which both fall under the jurisdiction of Federal governments in Canada and the United States. Land affected by the mine will also deprive water fowl from nesting sites and feeding on grain fields. The slough on my property also provides a habitant for wildlife.
Deer and other wildlife presently follow and feed along the creek which has tree cover providing habitant for wildlife. The trees also help to prevent soil erosion. The loss of any trees has an impact on the hydrology cycle in a region.
Transportation of products, increased traffic, and strip mining and gasification plants will for ever alter this land scape where four generations of our family have lived and farmed. Now we face the possibility of expropriation so that coal can be processed to supply a product to process oil sands so that we can supply more oil to the United States. The mission of many energy companies these days is to maximize return for shareholders and executives.
Air quality cannot help but suffer, yes the say they will try to find a market for C02; produced by the gasification plant however, if they do not they will bury it. This does not capture the increase in air pollutants fiom traffic, trucks, caterpillars, back hoes, draglines and other equipment associated with the mine.
Water that presently travels in the coal seams through out the area and on to the Battle River will cease. Tree cover on the first three townships, to be strip mined, will be absent for years to come. It appears that Sherritt International wants as little public input from the community as possible. I would like to have a reasonable amount of time to research the effects of, as well educate myself on the potential effects from strip mining development and coal gasification.
The east slope of the Beaver Hills hss b- provides the beginning of a unique habitant that extends west to Hi way 21 and runs north of the Battle River through Elk Island, a Federal Park, to Lamont. Prior to settlement for agriculture this area was frequented by local Aboriginal people. Evidence of their presence can be seen in many of the stone tools, some of which can be seen in the Tofield Museum. Any cultural or historical sites will be obliterated by strip mining.
These are some of my concerns, had I been notified earlier by Sherritt International I might have been able to find answers to my concerns by this time. How ever due to Sherritt International trying to fast track this project with as little community input as possible I have not had time to investigate all of my concerns. I have not yet had time to research the potential effects of heavy metal concentrations and tailing ponds. With Beaver Hill Lake suffering from low water levels will these tailing ponds become habitat for migratory water fowl? Regards, .. \"&:*'l/- Lr -*+ -. O ,' <' d' LEROY WHILLANS & SHARON WHILLANS Telephone 662.3828 or 232.2713 or 668.6037 or 289.6037 or 910.8967 or 965.6037. Area code 780. My preferred contact number is 232.27 13 and 662.3828.
CC available on request PAGE 04/05
Edwin C. Williams W1Ohaton AB TOB 3PO NW 21-47-18 W4
*,t780-679-2609
February 2 1,2007
Director, Environmental Assessment, Central Region ALBERTA ENVTJlOrJMEm 111, Twin Atria Building 4999-98 Avenue EDMONTON AB T6B 2x3
Re: Dodds-Round Hill Coal Gasification Proiect in Alberta
I am writing to you to express my opposition to the Dodd-Round Hill Coal Gasification Project currently proposed by Sherritt. For the past 1,8years T have owned and operated a mixed farm just south of Round Hill. Although I am not a rcsidenl directly in the prgoscd minc am, this project will greatly affect my family home as wcll as my livcIihood, as well as those of my neighbours.
I am vqconcmned that the disruption to the coal bed aquifms brought about through the proposed strip mine could have a devastating acct on my water wells. In addition, the natural watershed of the area will be an my .-..' Sisturbed, affecting wildlife and runoff. As a~culturalproducer, livelihood depends on water and its continued availability. We are dependent on well water for our housahold and farm we, My land will be worth. very little if there is no watar supply. This concern is in addition to my alarm at the incredible amount of water proposed to be piped in from the North Saskatchewan River. Having recmtly come through a drought I undmstand what a devastating effect a lack of water will havc on my livestock, crops and family. I am grcatly concmed about our diminishing fresh watcr supply even without the added pressure of this project.
In addition, a project of this magnitude will havc far reaching effects on the demand for infkastmcturc, and will cause an increase in pollution and greenhouse gas enu'ssions. Wl~owill be covering the costs of additional roads, health care., garbage clean up and policing that will bc ncccssasy? Even with reclamation, the land actually involved in thc strip mine, as wcll as thc large area which will house the proposed plant(s) will be unsightly and the short tern economic benefits are simply not worth the long term cost. Naturai treed areas could be destroyed and will take many decades to grow back - will the reclamation plans by Sherritt include this? The disruption of the wetlands and natural waterways of the area could be permanent.
Please consider the wishes of the residents of the proposed mine area as well as those in the surrounding area before proceedi.ng with this project.
Sincerely, #---
Ed Williams
''.----.ccRound Hill Dad& Protective Association PAGE 03/05
Norma IW I Ohaton AE TDB- 3PO NW21-47-18W4 780-679-2609 ..__. ,;ebruary 24 2007
Director, E&md Ars~sqCentral Region ALBERTA ENVIRONMENT ALBERTA ENVIRONMENT 11 1, Twin Atria Bddq 4999-98 Avcnue EDMQNTONAB T6B 2x3 Regional Services Central Region Re: .Qdds-h.md Hill M; Prnira
I am writing to you to cxprcss myverydeep concern about the Dodd-Round Hid 6at Gasification Pmject curri?ntlypmposed by Sh& I have attended rhc public consulmtion meetings (held this winter), as well as ,studied the Public Djsclmure document provided by Sherritt, and although the She& staff and publications are pmfessi~~dand thorough, I am greatly darned at thc scope of chis project and TRish to voice my opposition
My husband and I sdedon a farm just soutb of Round Hill. iu 1.989, Our fanipmduces forage and beef cattle. We have worked ditgentlyto be environmdymd socially responsible in our !arm practices. Although then is no doubt in my mind that our rutx1 -a could use an cconomic boost, the mvimnmend costs associated 6ththis project arc simply too great to justify the benefits.
Myfirst and foremost concern is mw - both the significant q&ments &at cbe gasifkation plant dd*quire (without eim considering the option of a second plant) as wen as the damage to the mte~hel,and aquifers that a huge cod strip mine wd.dcame. We arc cntcring a ncw era here in Canada - one where WE mn no lower take our b.&..na'tilralm~-f~r-~c~.Wh the ment PC.report on Global Warning it seems ludicrous to me that a project of this nature ieven considered. We can not condone the use our precious frcsh mter nsomes to prcduce futther plastics and fossiI fuels that contitme to destroy the enviromcnt. As an agricuId pdu~r,out livelihood dependF on water wd h continued availability. AS a person hq in the area and dependent OM dlmwr for our household use I am very concerned about ehc dcplccion of thc aqwfers chat we tap kto for our water supply- a landoarwho's '.._.~rer supply is at risk - what will lx the "fair marht value" for myland whcn chcn: is no water? This could be devastating for us as our livelihood and ~~tmentsare tied to our fa= What will happen when we start to have a shortaee-.ofwdter? This is happenidg NOW As the glacier that feeds rhr Norrh Saskatchcm River contima to recede, dowiug another huge user to draw from this rim is unacccptablc.
She& has admitted a coal. gasification plant wii produce significant greenhouse gas emissions. Again, in light d the recent PCZleport, allowing a huge multinational to tap into the cdfields under Albcrta w;U continue to WvatcCanada's poor record on dwhg greenhouse gas e&siom.
Shc& prcdicts that r.hc project muld Iast approximately 50 years. We need to have a vision for Alberta that tiansccrids the he2 and now ;\nd look inm the 10% term future. How- we consider ktting fqmdyfamthat have been in a farnilyfor 100 gears bc bought out by a mine? Who wiU want to fann it 10 years after it has been mind md is Ejnally "reclaimed"? Who will want to rive next to this mint and the .. huge plants proposed? I[ have no doubt that the reclaimed land will be able to be pt.inta pd~cdon,but the nad,Iandpattern, trees. creeks and wildlife will be altered fomer, Is the land "better" if we change a qwmr scction that used to have a mixture of natural mdmcl, bush and cultivated land w onc that is compkcelycul~d?What about the water, ddlife, soil coasc~odWhat about balance and mahug the area one in which people want to live? Are thcre any acsin pur neigbbourl~ood?The &e bm&t about by trees and wcthds arc ohnignoxcd, but rbc value they bring is undeniable and ixnplaceable.
The other affects of Iiving next to P huge project of this nature include noise, pollution, increased pressure on infrastructure and an incrcasc in crime. f am swypu appreciate the fmgility of our environment and the fact is kcthis do impamble damage. There are many landholders in the amwho are opposed to this project
?h.d you in advance for coasidering &c affect this projcct will have on the lives of the midm of the area The Gavcmm of AIberta must act now to encourage projects that are s.cidlymd en*.mnraUy~e. The ShedCoal Gasification plant is ncirhcr. Zlne mood in Albcm is s&g and Albelrsvrs no longer mtto rely on an economy built around unrentmbk cncrgy resowres. We need to shift our focus and act in such a mythat we protect and restore the envimnmcnr,
A&. Norma Williams
cc RmdHill-Doddq Protective Association