Comments for the Joint Review Panel's consideration in regards to the proposed Grassy Mountain Coal Project, by Benga Mining Limited

To Whom it may concern,

I am submitting my comments for the Joint Review Panel’s consideration in regards to the proposed Grassy Mountain Coal Project, by Benga Mining Limited.

I am a Canadian citizen and resident of Southwestern Alberta in the foothills of the Rocky Mountains. I am the fifth generation of my family to call southern Alberta home.

I am asking that the proposed Grassy Mountain Coal Project, by Benga Mining Limited be rejected and the project abandoned.

This proposed project is to be situated in a particularly important and vulnerable ecosystem. We must be aware that we may not be able to restore this area to its current condition after this project concludes and we must question the wisdom of such damage in the Canadian Rockies weighed against the meager potential benefits this project offers.“The original intention of the Coal Policy was to ensure that there were appropriate regulatory and environmental protection measures in place before new coal projects were authorized—this objective is being met by today’s modern regulatory, land use planning and leasing systems” (Government of Alberta, Coal Policy Guidelines https://www.alberta.ca/coal-policy-guidelines.aspx). It is not clear from this project that this objective is indeed being addressed by the current regulatory system. As a resident of the region I have grave concerns regarding the responsibility of this project and the long term harm versus the short term benefit being contemplated here. Nor do I have faith that the current process address or contemplates all potential values at play here, whether they be ecosystem services or aesthetic values as well as economic.

This project is located in the headwaters of an important watershed which supplies vital water resources that have been largely already allocated to previous users. We must be aware of the potential impacts/dangers to both water quality and quantity that this project poses. These water supplies are vital to agricultural production, domestic uses, as well as ecosystem health in the basin. As an Albertan the long-term sustainability of our communities as well as our ability to produce adequate food supplies in both quality and sufficient quantity to address our growing needs is of pressing concern. As time progresses and with the growing threat of climate change we must guard our precious water resources.

This proposed project location would also have significant impacts on wildlife, fish. We have continually encroached on the habitat of these species, it is a shame to contemplate damaging further the protected areas which shelter them. These species are not only important to our ecosystem health, but are also important to human use such as hunting and fishing. Providing sustenance, recreation and tourism.

Aside from local or provincial impacts. There must be a degree of concern regarding harm caused to water quality and quantity as this particular watershed (Saskatchewan River Basin) in question flows all the way to the Hudson bay, crossing provincial boundaries containing approximately 3 million people living within the Basin (Old Man Basin Advisory Council, https://oldmanwatershed.ca/about-the-watershed). This watershed is also linked to the St.Mary’s river which lies upstream. It is well understood that in such situations harm can move downstream or upstream from actions in the basin whether it be in water quality, quantity or in ecosystem health (for example fish populations). Here in the context of an international watercourse governed by the boundary waters treaty we must be exceptionally cognisant of potential upstream harm caused to our riparian neighbour.

According to Alberta Jobs, Economy and Innovation (Statistics Canada Visitor Spending Model for Alberta – 2018 numbers) In 2018, tourism spending by visitors to Alberta contributed to the provincial economy with: 68,800 tourism jobs (full-time equivalent employment in person years); $6.5 billion in contribution to Alberta’s GDP ($3.9 billion direct, $1.5 billion indirect and $1.1 billion induced); $1.1 billion in contribution from taxes on products and services, including: $531 million in federal tax revenue; $367 million in provincial tax revenue; $169 million in local tax revenue.

Sustainable recreation opportunities on provincial Crown land should be maintained. It has been a point of pride for me as an Albertan to have expansive public lands accessible for recreation to all Albertans as well as visitors to our province. Our public lands, in the Rocky Mountains  especially, provide a strong incentive to tourism in our Province.

As Albertans we enjoy world-class outdoor recreation. It is a legacy we have inherited and one we should protect. It is s a reason to proudly call Alberta home. As a fifth generation southern Albertan I am keenly aware of the debt I owe to past generations which have left this incredible legacy for me to enjoy, I am also keenly aware of the burden of responsibility that I have as an Albertan to pass this rich legacy on to my children and the generations of Albertans to come.

The potential benefits of this project do not appear to be far reaching or compelling, as a foreign owned project much of the benefits would not be felt here in some cases potentially long after the lifespan of this project, while much of the impacts would. It is not clear to me as a citizen of Canada and a resident of southern Alberta that this would be a worthy investment of our natural capital for future long-term benefits.

Again I am asking that the proposed Grassy Mountain Coal Project, by Benga Mining Limited be rejected and the project abandoned.

Thank you for your consideration of my comments.

Sincerely,

Riley Denoon