Hello Panel Members and Secretariat

My wife and I both made submissions to the panel on the 3rd day of the hearing as partial participants. Since then we have been following some of the proceedings. You will have heard many submissons and subsequent cross examinations, and read reams of data and I am sure your minds must have wandered away from the task in hand on a few occasions. I suspect the harder part of the task is ahead of you.

Some things from the hearings really stand out for us:1. The testimony from Cornelis Kolijn, the former Teck Coal geologist, who was introduced by Drew

Yewchuck at the 6 hour 41 minute mark of the proceedings on November 3rd. His analysis of the coal seams and statement that Benga cannot maintain their claimed coal quality for more than a few years of the mine’s life really puts in doubt the whole financial viability of the project. It would seem that in later years of the project the coal would be not much better than thermal coal and that kind of mine is being phased out in Canada. This means that the mine would likely not recoup costs as soon as predicted implying even less revenue for the provincial and federal governments. Clearly Cornelis knows far more about coal than Benga. They could not challenge his analysis.

2. The testimony from the MD of Ranchlands. They don’t want a mine in their municipality despite the fact they would receive $900,000 a year in property taxes which would be a large increase to their tax base. This really shows they care for the land and their residents who derive their livelihood from it. On the other hand the Crowsnest Pass municipality is desperate for an industrial tax base so wants the mine.

3. The statement by John Lawson, part of the Livingstone Landowners Group, starting at the 4 hour mark on November 4th. This testimony covers all the main issues that we are concerned about and he outlines them in a very matter of fact way and only goes into detail on a few of them. This is probably the best example of a broad ranging presentation by a regular citizen to the panel.

4. The cross examination of the Municipality of Crowsnest Pass’s so called expert, Mark Wittrup, at about the 2 hour mark on November 4th. He clearly had not executed a full examination of the EIA and the assumptions made by Benga so his report to the municipality has very little value. It would seem he was employed to just say Benga is good for the municipality. They want the mine!

5. The testimony of the only person under 30 to present to the panel. Stephanie was introduced by Rick Cooke of the Crowsnest Conservation Society early on November 4th. I will most likely be dead in 20 years. She will have half her life ahead of her after this mine, if approved, is finished. This community is only just recovering 30+ years after the last mines closed here. Some witnesses have stated the population of the community is declining. This was true until the 2011 census but the 2016 census showed a very small increase in population (as per Wikipedia). And my wife and I were part of that contributing to the “lifestyle economy”. This is the crossroads the community is at as Stephanie so well described. Either (a) a slow but sustained growth in a recreation and tourism economy, or (b) another short lived boom then bust followed by 30 years worse than it is now.

6. The many references to selenium in the water for downstream communities and that this is an issue for Montanans downstream from the Elk Valley despite huge sums of money having been spent to try to eliminate it. If Teck cannot solve this problem then it is unlikely Benga will.

I do not think the issue of wind was adequately covered by Benga in their EIA as I stated in my submission. It seems that no one else has fully addressed the reality of the wind here for the Panel and that the base wind, used by Benga to state that the wind only exceeds 30 kph in 3.2% of the hours in a year, does not tell the full story. Gavin Fitch, while cross examining Benga’s wind

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spokesperson, did not even pursue the real issue of gusts. The Benga spokesperson seemed to assume one gust a day from the November 2020 Crowsnest climate data that Mr Fitch presented and said that would be just 2 seconds. These gusts occur every minute or so, not just once an hour or once a day. The problem is that the hourly gust data only seems to be available for a very short time and are not in the climate history data area of the Environment Canada website.

The link below is an image from facebook of the wind warning sign at the junction of Highways 3 and 22 maybe 15 kms east of Blairmore during the night of 27-28 Nov 2020. 173 kph. On 29 December 2018 the sign that was here buckled in the 187 kph wind.When Gail and I drove past the sign at about 9:00 am on 15th November 2020 it read 102 kph.

https://climate.weather.gc.ca/climate_data/daily_data_e.html?StationID=10890&timeframe=2&StartYear=1840&EndYear=2020&Day=28&Year=2020&Month=11# andhttps://climate.weather.gc.ca/climate_data/daily_data_e.html?StationID=10890&Month=12&Day=1&Year=2020&timeframe=2&StartYear=1840&EndYear=2021 These are the links to the November 2020 and December 2020 daily data for Environment Canada’s Crowsnest Station, which I include below are below.

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These 2 tables/links shows that there are gusts over 30 kph on almost every day.

I have recently found another site with Crowsnest wind data.https://crowsnest.weatherstats.ca/charts/wind_gust_speed-hourly.html shows hourly wind gusts going back 10 days from the current date in a graph

During the final day of testimony Mr Fitch introduced a wind expert and it was interesting that he had a completely different formula for predicting the effects of wind on dust as compared to Benga’s spokesperson. I do not know who is correct, I hope you will get to the truth of all this.

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The following photos were taken at about 5000’ elevation on the ridge NE of Coleman and immediately west of Grassy Mountain (which is higher than 5000’) and I have not slanted the camera! The views look SE towards Turtle Mountain and the town of Blairmore. Trees do not grow like this if the wind is less than 30 kph!

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The issues of the effect on tourism and recreation related business did not receive much attention. Heather Davis spoke on November 4th as part of Crowsnest Conservation Society about her business and how it would be affected. There seems to be no data to suggest how much other areas of the Crowsnest Pass economy will decline if the mine is approved. And how many of the “weekenders” who own 30% of the houses in the municipality will continue to maintain a residence here as well.

My wife and others talked about alternatives to metallurgical coal for making steel. Just today, 28th December 2020, we came across an article about Mitsubishi Heavy building the world’s largest zero carbon steel plant in Austria that will produce 250,000 tons of steel a year. See https://asia.nikkei.com/Spotlight/Environment/Climate-Change/Mitsubishi-Heavy-to-build-biggest-zero-carbon-steel-plant . Yet another nail in coal’s coffin! We do not need a mine that the company will walk away from when the market for its product is not there. Then it would be us that pays for the cleanup.

In the event that you do approve this mine proposal (and I hope you won’t), I hope you will apply Rick Cooke’s recommendation that a time limit for the approval is used and that many conditions relating to the issues I have raised are part of the approval. I can foresee a situation where the Crowsnest Pass is in limbo wondering whether the mine will go ahead or not due to the company’s uncertainty about the fluctuation of coal prices and carbon taxes and how quickly all 4 markets for the met coal (China, Japan, South Korea and Taiwan) are working towards their goals of being carbon neutral by 2050.

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Yes, a mine will create some temporary jobs which would be good for some people and bring additional income to local businesses. But for how long with other technology on the horizon and at what long term cost to the community and the province in terms of remediation, water issues and more social benefits to be paid out after the company has long gone? Damage done to the environment by this and other potential mines will discourage any new business or residential activity in the area during the the life of the proposed mine and for a long time after there is no market for coal.

Alistair Des Moulins

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