Grassy Mountain Coal Project

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2019-12-20 0:00
  • Reference Number 302
  • fa9 di" UNIVERSITY OF CALGARY PUBLIC INTEREST LAW CLINIC FACULTY OF LAW MURRAY FRASER HALL December 20, 2019 SUBMITTED ELECTRONICALLY Grassy Mountain Coal Project Joint Review Panel Canadian Environmental Assessment Agency 160 Elgin Street, 22nd Floor Place Bell Canada Ottawa, ON K1A 0H3 Attention: Tracy Utting, Acting Review Panel Manager Re: Benga Mining Limited (“Benga”), CEAA Reference 80101, Grassy Mountain Coal Project The Inclusion of Planned Coal Mines in the Cumulative Effects Assessment The Canadian Parks and Wilderness Society Southern Alberta Chapter (CPAWS) writes to seek clarification on whether the Elan South Coal Project proposed by Atrum is within the scope of the EIA as an activity that will be carried out. CPAWS believes an advance determination would be efficient for all parties involved. CPAWS takes the position that the EIA must include consideration of the Elan South Coal Project as a

Attachment Administration

2019-12-16 0:00
  • Reference Number 301
  • From the Joint Review Panel to the Canadian Parks and Wilderness Society (CPAWS) Southern Alberta Chapter and Osler, Hoskin & Harcourt LLP on behalf of Benga Mining Limited re: Comments on the Grassy Mountain Coal Project (See Reference Document #284, #292 and #294)
  • From the Joint Review Panel to the Canadian Parks and Wilderness Society (CPAWS) Southern Alberta Chapter and Osler, Hoskin & Harcourt LLP on behalf of Benga Mining Limited re: Comments on the Grassy Mountain Coal Project (See Reference Document #284, #292 and #294)

Attachment Administration

2019-12-16 0:00
  • Reference Number 301
  • Dear Mr. Yewchuk and Mr. Ignasiak, Please find attached correspondence from the Joint Review Panel appointed to conduct the environmental assessment of the proposed Grassy Mountain Coal Project in response to correspondence from the Canadian Parks and Wilderness Society and Benga Mining Limited regarding hearing procedures. In accordance with the Canadian Environmental Assessment Act, 2012, comments received and other documents submitted or generated to inform the environmental assessment are part of the project file and will be posted on the Canadian Impact Assessment Registry (the Registry), reference number 80101, unless they are excluded due to confidentiality, security or other reasons. If you have any questions regarding this letter, you are encouraged to contact me at IAAC.GrassyMountain.AEIC@canada.ca. Sincerely, Tracy Tracy Utting Acting Panel Manager Grassy Mountain Coal Project IAAC.GrassyMountain.AEIC@canada.ca Grassy Mountain Coal Project

Attachment Administration

2019-12-6 0:00
  • Reference Number 300
  • Osler, Hoskin & Harcourt LLP Calgary Toronto Montréal Ottawa Vancouver New York LEGAL_CAL:14464151.3 December 6, 2019 Martin Ignasiak SENT BY ELECTRONIC MAIL Grassy Mountain Coal Project Joint Review Panel Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor Place Bell Canada Ottawa, ON K1A0H3 Attention: Alex Bolton, Chair, Joint Review Panel Dear Mr. Bolton: Re: Benga Mining Limited (“Benga”) CEAA Reference 80101 Grassy Mountain Coal Project (“Project”) Response to Information Request (“IR”) Package #6 We represent Benga in the above-referenced proceeding for the Project. We are writing in response to the letter from the Joint Review Panel (“JRP”), which was received by us on November 28, 20191 and which advised that following the review of Addendum 9 and 10, public comments received, and sufficiency comments received, further information is required from Benga before proceeding to a hearing. The letter requested that

Attachment Administration

2019-11-28 0:00
  • Reference Number 297
  • From: <email address removed> Sent: Thursday, November 28, 2019 12:01 PM To: Grassy Mountain (IAAC/AEIC) <iaac.grassymountain.aeic@canada.ca> Subject: RE: Exposure to PM 2.5 was associated with increased brain atrophy I regret that relevant articles are rejected by the panel. They are far more convincing than my summary would be – and they hold critical information that the panel should be considering, especially the effects of air pollution from coal fly ash. This first application from Riversdale Resources and the others bound to follow are very frightening with respect to our health. Do we stay with friends and community in a landscape we love or are we pushed out of our home because we are not willing to put ourselves at risk to coal effluent that could kill us with lung or heart disease or cross the blood brain barrier and cause dementia. Would you or the panel like to have this choice? I send reports of studies already parsed into easy reading by credible

Attachment Administration

2019-11-20 0:00
  • Reference Number 294
  • PUBLIC INTEREST LAW CLINIC FACULTY OF LAW MURRAY FRASER HALL November 20, 2019 SUBMITTED ELECTRONICALLY Grassy Mountain Coal Project Joint Review Panel Canadian Environmental Assessment Agency 160 Elgin Street, 22nd Floor Place Bell Canada Ottawa, ON K1A 0H3 Attention: Tracy Utting, Acting Review Panel Manager Re: Benga Mining Limited (“Benga”), CEAA Reference 80101, Grassy Mountain Coal Project Reply to Benga’s Submissions regarding Procedural Questions The Canadian Parks and Wilderness Society Southern Alberta Chapter (CPAWS) makes these submissions in response to Benga’s submission of November 14, 2019 regarding procedural issues in relation to the public hearing process. Benga’s response to our procedural questions misconstrued CPAWS’s submission, but Benga’s reply does seem to indicate that a reasonable set of compromises can be reached. 1) CPAWS did not request a redrafted and reorganized complete EIA be

Attachment Administration

2019-11-15 0:00
  • Reference Number 293
  • From: <email address removed> Sent: Friday, November 15, 2019 10:28 AM To: Grassy Mountain (IAAC/AEIC) <iaac.grassymountain.aeic@canada.ca>; Grassy Mountain (IAAC/AEIC) <iaac.grassymountain.aeic@canada.ca> Subject: Millions of tonnes of methane from coal mines belched into atmosphere as policymakers overlook threat, researchers find Methane emissions from coalmines could stoke climate crisis – study Millions of tonnes belched into atmosphere as policymakers overlook threat, researchers find Jillian Ambrose Fri 15 Nov 2019 07.00 GMTLast modified on Fri 15 Nov 2019 14.25 GMT Shares 301 Coal collected from the Neryungrinsky mine in Russia The global energy watchdog estimates the amount of methane seeping from new and disused coalmines may have reached just under 40m tonnes last year. Photograph: Artyom Geodakyan/Getty Images The methane emissions leaking from the world’s coalmines could be stoking the global climate crisis at the same rate as the shipping and

Attachment Administration

2019-11-15 0:00
  • Reference Number 293
  • From: <email address removed> Sent: Friday, November 15, 2019 10:28 AM To: Grassy Mountain (IAAC/AEIC) <iaac.grassymountain.aeic@canada.ca>; Grassy Mountain (IAAC/AEIC) <iaac.grassymountain.aeic@canada.ca> Subject: Millions of tonnes of methane from coal mines belched into atmosphere as policymakers overlook threat, researchers find Methane emissions from coalmines could stoke climate crisis – study Millions of tonnes belched into atmosphere as policymakers overlook threat, researchers find Jillian Ambrose Fri 15 Nov 2019 07.00 GMTLast modified on Fri 15 Nov 2019 14.25 GMT Shares 301 Coal collected from the Neryungrinsky mine in Russia The global energy watchdog estimates the amount of methane seeping from new and disused coalmines may have reached just under 40m tonnes last year. Photograph: Artyom Geodakyan/Getty Images The methane emissions leaking from the world’s coalmines could be stoking the global climate crisis at the same rate as the shipping and

Attachment Administration

2019-11-14 0:00
  • Reference Number 292
  • Osler, Hoskin & Harcourt LLP Suite 2500, TransCanada Tower 450 – 1st Street S.W. Calgary, Alberta, Canada T2P 5H1 403.260.7000 MAIN 403.260.7024 FACSIMILE Calgary Toronto Montréal Ottawa Vancouver New York LEGAL_CAL:14410689.1 November 14, 2019 Martin Ignasiak SENT BY ELECTRONIC MAIL Grassy Mountain Coal Project Joint Review Panel Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor Place Bell Canada Ottawa, ON K1A0H3 Attention: Tracy Utting, Acting Panel Manager Dear Madam: Re: Benga Mining Limited (“Benga”) CEAA Reference 80101 Grassy Mountain Coal Project (“Project”) Response to CPAWS Comments The public comment period was initiated by the Joint Review Panel (“JRP”) on September 9, 2019, and closed on October 24, 2019.1 On October 31, 2019, we provided Benga’s response to the JRP in respect of the comments received and requested that the JRP proceed to a hearing on the basis that it has sufficient information

Attachment Administration

2019-10-31 0:00
  • Reference Number 291
  • Osler, Hoskin & Harcourt LLP Suite 2500, TransCanada Tower 450 – 1st Street S.W. Calgary, Alberta, Canada T2P 5H1 403.260.7000 MAIN 403.260.7024 FACSIMILE Calgary Toronto Montréal Ottawa Vancouver New York LEGAL_CAL:14402841.1 October 31, 2019 Martin Ignasiak Our Matter Number: 1167150 SENT BY ELECTRONIC MAIL Grassy Mountain Coal Project Joint Review Panel Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor Place Bell Canada Ottawa, ON K1A0H3 Attention: Tracy Utting, Acting Panel Manager Dear Madam: Re: Benga Mining Limited (“Benga”) CEAA Reference 80101 Grassy Mountain Coal Project (“Project”) Comments on Sufficiency We are writing in connection with the public comment period initiated by the Joint Review Panel (“JRP”) on September 9, 2019, which closed on October 24, 2019. Benga has reviewed all of the comments posted on the new Impact Assessment Agency Registry (“Registry”) as of October 25, 2019. We submit that a

Attachment Administration

2019-10-25 0:00
  • Reference Number 281
  • Joint Review Panel Grassy Mountain Coal Project CEAA.GrassyMountain.ACEE@canada.ca Proposed Information Requests on the Sufficiency and Technical Merit of the Environmental Assessment Participant: David Mayhood Organization (if applicable): FWR Freshwater Research Limited on behalf of Timberwolf Wilderness Society General Comments: The proponent’s counsel, Osler, Hoskin & Harcourt LLP (Osler), in a 31 January 2019 letter to Tracy Utting of CEAA (file 126671E.pdf), has made the following claims about Timberwolf Wilderness Society (Timberwolf), which we wish to address here. “…this Society has not previously engaged with Benga regarding the proposed Project. It has not previously expressed any interest in the Project or requested information from Benga, despite the fact the Project has been in the regulatory process for years already “ (126671E.pdf, p. 21). “…we note that the Society is opposed to all development in the region” citing Timberwolf’s web page in

Attachment Administration

2019-10-24 0:00
  • Reference Number 288
  • Livingstone Landowners Group <contact information removed> October 24, 2019 Grassy Mountain Coal Project Joint Review Panel Canadian Environmental Assessment Agency 160 Elgin St, Flr 22 Ottawa, Ontario, K1A 0H3 By Email: CEAA.grassymountain.ACEE@canada.ca Dear sirs: Re: Comments on Addendums 9 and 10 to the Grassy Mountain Coal Environmental Impact Assessment Thank you for the opportunity to comment on Addendums 9 and 10 submitted on behalf of Benga Mining Ltd. A brief analysis of information filed relating to human health impacts and associated contributing factors or conditions has been prepared on our behalf by Dr. Allan Garbutt, and follows this letter. Dr. Garbutt is a practising medical doctor, and has extensive knowledge and history of local conditions and the local community. Unfortunately, the Livingstone Landowners Group is not in a position at this time to make detailed comments on other information contained in Addendum 10 or in

Attachment Administration

2019-10-24 0:00
  • Reference Number 278
  • IFEOMA M. OKOYE, LLM ASSISTANT: SANDRA L. OUR FILE No. 154436 /IMO YOUR FILE No. 80101 October 24, 2019 EMAIL TO IAAC.grassymountain.AEIC@canada.ca Grassy Mountain Coal Joint Review Panel Canadian Environmental Assessment Agency 160 Elgin Street 22nd Floor Ottawa Ontario K1A 0H3 Attention: Tracy Utting, the Acting Review Panel Manager Dear Ms. Utting: Re: Grassy Mountain Coal Project, Reference #80101 Clients: Coalition of Alberta Wilderness Association and Grassy Mountain Group; and Shirley Kirby Comments on Benga Mining Limited’s Environmental Impacts Assessment As indicated in our earlier correspondence of January 21, 2019, we act for Ms. Shirley Kirby and the Coalition of Alberta Wilderness Association and Grassy Mountain Group (“the Coalition”). On September 9, 2019, the Joint Review Panel initiated a public comment period inviting the public to comment on the additional information submitted by Benga Mining

Attachment Administration

2019-10-24 0:00
  • Reference Number 282
  • From: <email address removed> Sent: Thursday, October 24, 2019 4:38 PM To: Grassy Mountain (IAAC/AEIC) <iaac.grassymountain.aeic@canada.ca> Subject: Public Comment Deadline & Brief Submission Dear Panel, Full participation in this process and the review of so much information requires resources in time and expertise that most NGOs and individuals like me simply do not have, especially when the information provided is so disparate, requiring endless cross-referencing. Today, however, is the deadline for comment so may I simply submit the following: 1. The fundamental premise, to engage in open cut – even mountaintop removal – coal mining in the 21st century, is simply wrong and nothing in the new information submitted by the proponent can effectively ameliorate this basic premise. 2. Knowing what we know about the extremely serious – even existential – consequences of burning coal, especially coal that is near 80 percent carbon, how can we morally justify the

Attachment Administration

2019-10-24 0:00
  • Reference Number 290
  • Review of Human Health impacts from proposed Grassy Mountain project. This review led inexorably to a review of air and water aspects of the project. That review also, unfortunately, shows that much of the human health impact assessment (HHIA) rests of faulty and suspect assumptions. The most obvious relates to wind speeds and thus to the dispersion of pollutants and other materials from the mine site. The chart submitted by Benga shows almost no time with wind speeds greater than 60 km per hour (KPH) at any of their monitoring sites. To accept that as an accurate representation of winds in this area requires that Benga staff have spent almost all their time in Blairmore securely sequestered in the office. For much of the time between November and April, the Environment Canada forecast for this area will include a wind warning. Those warnings are only issued when winds are expected to exceed about 80 KPH. Speeds over 100 KPH are not uncommon. Last winter had

Attachment Administration

2019-10-24 0:00
  • Reference Number 280
  • October 24, 2019 Joint Review Panel Grassy Mountain Coal Project Further to our previous letters regarding our opposition to the Grassy Mountain Coal Project, we’d like to express our concern regarding this project moving forward. First, given the environmental concerns so many have expressed, the list is endless. Contaminated wells, contaminated water, destruction of wildlife habitat, noise pollution. Never mind the effect it will have on our property values. Secondly, if given the ‘go ahead’ on the Grassy Mountain project, Benga Mining still has not addressed the above concerns after numerous requests to do so. They say they will remedy the above concerns but they don’t detail how this will happen. It has recently come to our attention that 3 other mining companies are exploring this area. We know this is at its early stages and doesn’t have anything to do with Benga’s application, however, some consideration must be given to the density

Attachment Administration

2019-10-24 0:00
  • Reference Number 286
  • 000914-0004.0001 00543004.2 Rosanne Kyle October 24, 2019 VIA EMAIL - CEAA.GrassyMountain.ACEE@canada.ca Grassy Mountain Coal Project Joint Review Panel Canadian Environmental Assessment Agency 160 Elgin Street, 22nd Floor Place Bell Canada Ottawa, ON K1A 0H3 Attention: Tracy Utting Acting Panel Manager Dear Ms. Utting: Re: Grassy Mountain Coal Project (“Project”) - Comments on Ninth and Tenth Addendum We are writing as legal counsel for Tsuut’ina Nation (“Tsuut’ina”) to provide comments to the Grassy Mountain Coal Project Joint Review Panel (“JRP”) regarding the sufficiency and technical merits of the Ninth and Tenth Addendum to the Environmental Impact Statement (“EIS”). We note that given the time constraints we were not able to do a full technical review of the submissions, and understand that the proponent is opposing an extension of time for Tsuut’ina to undertake a full review. On February 15, 2019 we provided tables setting out

Attachment Administration

2019-10-24 0:00
  • Reference Number 289
  • October 24, 2019 Panel Secretariat Grassy Mountain Coal Project Canadian Environmental Assessment Agency 22nd Floor, 160 Elgin St. Ottawa ON K1A 0H3 Telephone (Toll-free): 1-866-582-1884 CEAA.GrassyMountain.ACEE@canada.ca Dear Panel Secretariat, Re: Information Request for Grassy Mountain Coal Project (80101) following 9th and 10th Addendums. Yellowstone to Yukon Conservation Initiative (Y2Y) is in agreement with the Proposed Information Requests relating to the sufficiency of the EIA submissions for Grassy Mountain Coal Project as submitted by the Canadian Parks and Wilderness Society (CPAWS) Southern Alberta Chapter on October 24, 2019. In addition to the Proposed Information Requests by CPAWS, Y2Y submits two additional Proposed Information Requests on the Sufficiency and Technical Merit of the Environmental Assessment (attached). To address cumulative effects over a large landscape, past, current and future human uses that degrade

Attachment Administration

2019-10-24 0:00
  • Reference Number 287
  • Joint Review Panel Grassy Mountain Coal Project CEAA.GrassyMountain.ACEE@canada.ca Proposed Information Requests on the Sufficiency and Technical Merit of the Environmental Assessment Participant: Jim Lucas Organization (if applicable): Not applicable General Comments: I have previously submitted a comment regarding this project. One of my main concerns was Riversdale’s choice for the coal loadout. At that time, the Golf Course Figure 8 was presented by Riversdale as the “public’s preferred choice” (from a selection from which they excluded locating the loadout near the coal processing plant). Per Riversdale’s August 2016 Project Update Section A.7.3.1, they state for the Blairmore Creek Trail Track #1 option “The technical rating for this option is tied for second and is considered technically feasible.” They further consider the economic analysis but fail to adequately address the social costs of their choice namely proximity to the town of

Attachment Administration

2019-10-24 0:00
  • Reference Number 283
  • <contact information removed> <Original signed by> Environmental Protection Operations Directorate Prairie & Northern Region 9250 49 Street ECCC File: 4194-10-3/6188 Edmonton, AB T6B1K5 IAAC Registry: 80101 October 24, 2019 via email at: CEAA.GrassyMountain.acee@canada.ca Alex Bolton Chair, Joint Review Panel for the Grassy Mountain Coal Project c/o Impact Assessment Agency of Canada 160 Elgin Street, 22nd Floor, Ottawa, ON K1A 0H3 Dear Alex Bolton: RE: 80101 – Environment and Climate Change Canada’s Sufficiency and Technical Review of Benga Mining Ltd’s Addenda 9 and 10 to the EIA for the Grassy Mountain Coal Mine Project On September 9, 2019 the Joint Review Panel (the Panel) submitted a public notice inviting public comments on the Ninth and Tenth Addenda to Environmental Impact Assessment (EIA) for the Grassy Mountain Coal Project. Environment and Climate Change Canada (ECCC) has reviewed the material and is providing

Attachment Administration

2019-10-24 0:00
  • Reference Number 284
  • c/o Canada Olympic Park 1 October 24, 2019 SUBMITTED ELECTRONICALLY Grassy Mountain Coal Project Joint Review Panel Canadian Environmental Assessment Agency 160 Elgin Street, 22nd Floor Place Bell Canada Ottawa, ON K1A 0H3 Attention: Review Panel Manager Re: Proposed Information Requests for Grassy Mountain Coal Project (80101) following the 9th and 10th addendums, and Questions Regarding Hearing Procedure Please find attached a document of Proposed Information Requests relating to the sufficiency of the EIA submissions for the Grassy Mountain Coal Project. The Canadian Parks and Wilderness Society Southern Alberta Chapter (CPAWS) further asks the panel to consider and make decisions regarding several procedural issues about the public hearing process at this time. 1) CPAWS notes that the Joint Review Panel has previously requested a single, comprehensive, easily read response that compiles all the information generated for the Environmental

Attachment Administration

2019-10-24 0:00
  • Reference Number 279
  • To the Joint Review Panel and Secretariats, Thank you for the time and consideration for this dauntless task of pouring through the information provided and asking appropriate questions from the applicant. As a land owner on Gold Creek adjacent to the mine site for 27 years, i am exhausted with keeping up with the whole application process. A lot of very smart people have asked and stated concerns regarding Benga, Riversdale, Hancock application to mine coal in Southern Alberta in the headwaters of the Old Man River water shed. This in its self sounds very disturbing. In the beginning I have thought their land, do as they will, it is their land. After reading the ninth and tenth amendment and responses I see the agenda as not being in the public best interest. Some points in the original application stated 25 years of mining, 2 years reclamation. some where i have read the application includes the wording of 100 years. Unacceptable. Also, wordings of taxes

Attachment Administration

2019-10-21 0:00
  • Reference Number 277
  • From: Blair Painter <email address removed> Sent: Monday, October 21, 2019 11:11 PM To: J Yanota <email address removed>; Grassy Mountain (IAAC/AEIC) <iaac.grassymountain.aeic@canada.ca> Cc: <email address removed>; Livingstone-Macleod <email address removed> Subject: RE: Grassy Mountain Mountain Coal Project Hi Jay. Thank you for forwarding us the documents that you sent in to the Review Panel for our review. Like you, I also am a resident that was born and raised in the Crowsnest Pass, with family ties going back to the early 1900’s and support the Riversdale Project. The Crowsnest Pass needs the jobs and the tax base that an industry of this calibre will bring. Kindest Reguards Blair Painter to our community Blair Painter MAYOR Municipality of Crowsnest Pass P.0. Box 600 | Crowsnest Pass, Alberta | T0K 0E0 <contact information removed> From: J Yanota <email address removed> Sent: October 17, 2019 3:25 PM To:

Attachment Administration

2019-10-21 0:00
  • Reference Number 275
  • October 21, 2019 Dear Panel Manager: We have the following questions and concerns regarding the Ninth and Tenth Addendum. Addendum 10, Package 5, Pg. 24 says: “Further, this approach has been implemented and is providing excellent results at the Teck Elk Valley facility where an SBZ has been in operation since 2017.  Notwithstanding Benga’s confidence in the selenium removal concept using an SBZ, Benga also recognizes that the concept needs to be implemented well, in consideration of the specific parameters of the Project in order to achieve the excellent results that are possible. That being the case, Benga has and will continue to implement testing and other R & D initiatives to progressively develop the detailed engineering parameters for the first phase of the SBZ which will need to be implemented by ‘Mine Year 4’ after Project construction begins (which in calendar years includes two years of construction and five years of operations). Based on modelling of the

Attachment Administration

2019-10-18 0:00
  • Reference Number 272
  • From: Violet Meguinis <email address removed> Sent: October 18, 2019 2:44 PM To: Grassy Mountain (IAAC/AEIC) <iaac.grassymountain.aeic@canada.ca> Cc: Tanis One Spot <email address removed>; <email address removed>; Declan Starlight <email address removed> Subject: Grassy Mountain Coal Project - Tsuut'ina Nation - Request for Extension Dzinisi guja (good day), We formally request a two week extension to submit our comments on the ninth and tenth addendum to the Environmental Impact Assessment, given the size of the addendums (over 3,000 pages) and new analysis and reports, we require additional time to provide fulsome comments and information requests as required. Please send verification that our request has been received and whether it can be accommodated. Siiyisgaas... Siiyisgaas! (thank you) Violet M. Meguinis, B.Ed. Consultation Director Tsuut'ina Nation Consultation - 3rd Floor Chief Joseph Big Plume Building <contact information

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