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Strongly Opposed

Reference Number
4956
Date Submitted
2021-01-15 5:58:29 PM
Text

Thank you for the opportunity to comment on the Grassy Mountain Coal Project proposal. I am writing to urge you to reject the project and other coal mines along Alberta's eastern slopes. (The southern Rocky Mountains) Reasons for my opposition are as follows.

Is this the future we want? What is the benefit of a short-sighted cash grab, with long-term ecological consequences?

Landscapes stripped open is a slow motion physical and psychological natural disaster. There is an opportunity to protect our environmental amenities for the well-being of Albertans, and our visitors. Applications and plans for coal mining exploration and development threaten the ecological integrity of Alberta’s eastern slopes.

Promises and dreams from Benga Mining and the Coal Association of Canada, claim that this is an investment in the future of Canadian export coal mining operations. But a strong case can only be built on a foundation of favourable markets for coking coal. Additional uncertainties include:

  • Evolving steel making technologies. According to the World Steel Association (WSA), electric arc furnaces (EAF) use roughly 80% less coal to produce steel than the blast furnace method. China and India are rapidly increasing EAF use for crude steel production. WSA data shows China’s EAF production is 434% higher in 2018 than in 2000; India’s 2018 EAF production was 521% higher than in 2000.
  • Premium coking coal threshold. Is the quality of coal high enough to receive the premium coking coal benchmark price? Or will it only produce a second tier, hard coking coal?
  • Royalty forecasts. Royalty forecasts are unreasonable and unsupported.

Without the Coal Policy, Alberta runs the risk of indiscriminately approving coal exploration and development without a regulatory framework that can effectively foresee and manage cumulative effects across all land use activities.

This project and others in the region must not proceed for the following additional reasons:

  • The Eastern Slopes are the backbone of Alberta’s wilderness. They encompass the vital headwaters of the North Saskatchewan, South Saskatchewan, Red Deer and Oldman rivers, provide essential habitat for wildlife and species at risk, and support the recreational pursuits and livelihoods of many. 
  • There are serious concerns about the long term economic impacts of this project, especially as it pertains to reclamation, remediation and water treatment costs.
  • The precedent will be set. Are applications that are disorganized, deficient, and apply a make-it-up-as-they-go approach approved? No matter how many questions and concerns around modelling and assumptions remain after five-and-a-half years. 

These are reasons enough to deny this application.

Thank you for your time and service to the Canadian public.

Sincerely,

Jamie Jack

Submitted by
Jamie Jack
Phase
N/A
Public Notice
N/A
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