April
11, 2016
Lac
Le Jeune Conservation Association
PO
Box 5044
Lac
Le Jeune, BC
V1S
1Y8
To
the Environmental Assessment Office:
During
the public comment period, the Lac Le Jeune Conservation Association (LLJCA)
organized a distributed review of the studies in the KGHM Ajax Application/EIS
that are relevant to conservation and quality of life in our community. In
addition, members of LLJCA participated in public information meetings, and
read available expert reviews of the Ajax Application, namely those contracted
by Kamloops City Council, Kamloops Physicians for a Healthy Environment, Kamloops
Moms for Clean Air, Kamloops Area Preservation Association, and Sierra Club BC.
We share the concerns raised in these expert reviews, and are extremely
grateful for these contributions to the dialogue about a proposed mine situated
in close proximity to residences, and in an area abundant with excellent
natural resources and recreation.
The
members involved in the LLJCA review generated a list of key concerns and questions
related to our area. They do not include the equally serious concerns shared
with Kamloops residents, such as those relating to health hazards,
disadvantageous changes in atmospheric conditions, excessive removal of water
from the Thompson River/Kamloops Lake reservoir, in a time of diminishing water
reserves through loss of glaciation and the adverse impact on the biota in the
working area.
Lac
Le Jeune is approximately 9 kilometres south of Goose Lake Road, which
essentially marks the beginning of altered landscape to accommodate the proposed
Ajax Mine. As well, with our road systems in question, increased traffic related
to mine activity could be right at our doorstep. As a community, the location
of Ajax Mine concerns us a great deal.
Overall,
the conclusions we have drawn from this process is that the the Ajax Mining
studies consistently underestimate the mine’s effects on our environment during
all phases of the project. Furthermore, there are flaws in the research methods
used in these studies.
Given
that many of the issues span several studies and reports, we have not attempted
to categorize our list to align with the sections outlined in the Ajax Mine
Application. Instead, we are using a simple framework comprising 4 categories.
For efficiency, we have listed our comments in point form.
- Pollution
and Environmental Disasters
- Fish
and Wildlife
- Health
and Safety
- Recreation
1. Pollution and
Environmental Disasters
- Everything
in the environmental report is based on the best possible outcome from
steps Ajax proposes to take to reduce problems. They should be reporting
what the worst possible results from mine operation might be.
- There
has been an increase in litter on Lac Le Jeune Road, much of it a result
of commuter traffic from Kamloops to the Highland Valley Copper mine (as
reported by RCMP at our Association’s Annual General Meeting). A further
increase in traffic will no doubt result in more litter. How will this
issue be addressed?
- We
enjoy spectacular night skies in our area. We are not convinced from the
studies that light pollution will not an issue.
- We
have concerns with respect to various faults described in the
application. The use of the term “faults” were thought to indicate the
potential for instability in the area to be used for tailings ponding. In
the section on Geology, faults refer to interfaces between non or low ore
bearing rock basins and zones that are suitable for ore extraction. These
faults are ancient and stable (non -active) interfaces, and clearly they
would not constitute a threat with respect to earthquakes.
- We
request clarification of what is meant by the term “fault”, particularly
in relation to where it is used in reference to the Goose Lake and Edith
Lake zones.
- There
is a high level of concern over the use of Goose Lake as a tailing pond
retained by dams that have so recently, here in B.C. as well as other
places in the world ruptured with catastrophic results. The failure of a
tailings pond dam at Goose Lake would have serious consequences to the
environment and potentially fatal consequences for human and animal life
in the downstream rangeland. Given the history of tailing pond disasters,
we question any guarantees against such failures.
- “Winter
conditions” were not evaluated. There would be a build of air borne
particulates on the ice, snow/ice cover, which would lead to a pulse of
contamination entering the water upon ice off. This would be unlikely to
change the composition of the contaminants but would result in a spike in
concentration, which could potentially increase the biological impact
significantly.
- Lac
Le Jeune is a direct source of drinking water for residents who are not
using wells. During the winter months we take measures to ensure that the
surface of the frozen lake remain free from contaminants, such as salt
from road maintenance, and pet dog feces. What will be the accumulation of
particles on the lake surface during the winter months? How will that
impact the quality of our drinking water?
- Biological
mitigation is not going to have a positive effect in the area immediately
surrounding the pit activity.
- Low
water flow/levels have the effect of increasing the concentration of
contaminants as well as heightening their impact as a result of the
simultaneous increase in water temperatures due to reduced volume.
- O2
levels drop with rising water temperatures and within a certain range of
temperature rise, certain biochemical reactions - e.g. production of
organic mercury through anaerobic bacterial action – will increase as the
O2 levels drop. Metals in organic form have a much increased impact on the
health of biota because they are more readily incorporated into the body.
- Low
flow/ levels provide ideal conditions for the growth of the blue green
algae, many of which produce undesirable or toxic metabolites in water
supplies. When blooms of these types of algae die off they add to the
organic loading in the aquatic systems and commensurate degrading of the
O2 levels during ice on conditions.
- Regarding
leachate of toxic waste from rock and ore extraction, we have read over
the parts of the application that deals with Jacko Lake, and note that
there have been studies on the likelihood of leaching of toxic materials
such as lead and arsenic from the rock extracted from the pit zone and
stored as waste rock. The rock itself and the surrounding area on which it
would be stored tests as basic in pH, which means that there is a low
potential for leaching of acid soluble material. This means that though
the rock and minerals within the rock may contain amounts of these
materials they are not likely to leach into ground water or aquifers. These
findings at least coincide with our knowledge of the alkaline nature of
the waters and soils of the area (Jacko Lake has an alkaline pH as do the
soils of the surrounding area). However, this does not mean that there are
not other chemical or physical mechanisms which may contribute to elevated
levels of toxic materials in Jacko Lake and Peterson Creek and associated
aquifers, but they would probably be slow developing, long term
contributors.
- The
studies were reportedly based on laboratory tests on rock and ore
samples and at least in part on rock residues that had been exposed during
previous open pit operations immediately east of the proposed site.
- Strategically
placed dams and enclosure constructs in the lake itself are the mitigation
methods for preventing out washed materials entering the Jacko lake water
system. These would not prevent the continuous deposition of fine airborne
materials entering the lake and adjacent stream waters. Since fish and
their spawn, as well as aquatic reared invertebrates, plankton and
phytoplankton are affected by fine sediments through chemical and physical
as well as through oxygen and light attenuation, continual deposition of
such sediments would continue to be a problem, if not immediately then
likely in the long term.
- Given
the size of these particles they would be subject to biological and
physical conditions in the aquatic environment that might increase the
release of materials such as arsenic and lead converting them to more
bio-toxic organic forms. We are unable to find any suggestions for
effective mitigation of this type of hazard. It would be very difficult to
manage given the mechanisms that will be productive of fine air borne
particulates – loading and transport of rock and fines, as well as blasting
etc.
- Peterson
Creek is an open water course through a residential part of the city as
well as in a park. How will the mine impact Peterson Creek?
- How
will drawing large quantities of water impact the level of the Thompson
River? If it drops much lower this is going to affect the Adams River run
of salmon.
- Where
will the tailings pond drain? A spill will surely flow out Peterson Creek
and into the river.
- The
studies do not deal with the effects of blasting on groundwater in
Aberdeen.
- It
was quite concerning that KGHM used mitigated soil as the starting base
for the study. A base line should always be of unaltered material.
- As
air quality is a significant concern, we request the studies are
resubmitted using a proper base line. Any subsequent studies that used the
initial results should also be resubmitted using the correct data.
- Was
data from both the Aberdeen and Federal Building Air Quality station used?
If so, was the data averaged between the two stations?
- Did
the air quality station in Aberdeen registered the occurrence of cloud
clover at that elevation?
- Did
the model include the regular occurrence of cloud bank at the proposed
mine elevation?
- Was
North-east winds registered and accounted for at the Aberdeen station?
- Were
the following gases registered and included in the study?
Ground-level Ozone (O3)
Nitrogen Dioxide (NO2)
Sulphur Dioxide (SO2)
2. Fish and Wildlife
- Low
water flow from April-September in Peterson Creek and Jacko will not meet
the needs of fish. There seems to be little in the way of mitigation on
this item.
- Is
there a plan if we reach drought conditions?
- Noise
and vibration from blasting will result in displacement of wildlife.
- The
Mine activity will likely result in animals that frequent this area in the
winter moving toward the city boundary, further increasing the nuisance
factor for residents.
- American
Badger is a red listed species and relies on the wetlands for it habitat
(which is going to be destroyed before/during the construction phase, so
impact will be bad).
- The
area around the Ajax site is a major overwintering habitat for both white
tail and mule deer. Neither of these species is on the endangered species
list but it will certainly affect them through displacement.
- Coyotes
fill an extremely important niche in the the area by helping to keep
rodent populations in check.
- We
are very concerned about the effect this project is going to have on the
amphibians and the western toad population in the area.
- There
is a large population of the western toads at the mine site. The proposed
mitigation is insufficient.
- There
are two Species at Risk blue-listed species of special concern. Even after
mitigation measures there will complete habitat and breeding habitat loss,
direct mortality and chemical hazards. This is unavoidable and will be
permanent and/or have long term effects. This contravenes the BC Wildlife
Act and the Species at Risk Act (SARA).
- There
is a large Western Toad population not identified in the application. They
migrate in large numbers across the Lac Le Jeune Road in the area around
Michell Ranch and Inks Lake underpass (approximate coordinates 50.613090 -
120.445136 to 50.618128 - 120.442969)
- Jacko
Lake is a breeding site for the Western Toad and has a large population. http://ca.geoview.info/little_toads_at_jacko_lake_bc,59944143p
- The
application shows that during the construction phase there will be a high
mortality rate from clearing/grubbing and public road realignments,
maintenance and supplies. There will be high habitat loss, so significant
in the Infrastructure footprints that “all habitat occurring within the
project IF is assumed to be permanently lost”.
- Claims
that a species will not be displaced refer to a habitat that will have
already been permanently been removed by Ajax. This type of claim is a
sleight of hands.
- Many
chemicals will exceed aquatic guidelines throughout various stages of the
project (arsenic, cadmium, chloride, mercury, selenium, sulphate, uranium,
ammonia, nitrate, cobalt, copper, molybdenum, antimony). They have shown
to have detrimental effects on amphibians.
- “After
the implementation of mitigation measures residual effects on amphibians
are anticipated to result from habitat loss, direct mortality and chemical
hazards. The loss of suitable amphibian breeding habitat will not be
avoidable and will have an effect on amphibian species present in the
LSA.”
- “These
effects will be present for the life of the project”
- Clearly,
there are going to be significant, negative, long term if not permanent
effects for these protected species. This is unacceptable.
- How
many western toads will be destroyed by the creation of the entire mine
site?
- How
will you manage the migration of any remaining western toads on a 24/7
basis?
- How
many western toads will survive after the 1st year of the mine site having
been cleared?
- There
are eight SARA red/blue listed bird species that are threatened/special
concern. Project effects include permanent habitat and breeding
habitat loss, direct mortality to birds and damages to active and non
active nesting sites. The BC Wildlife Act and Migratory Birds Convention
Act, protects migratory birds from being killed, injured or captured, nests
from being disturbed, damaged, destroyed or removed.
- The
merganser and yellow headed blackbird are both migratory.
- Jacko
lake and immediate surrounding environment act as resting areas or staging
areas during migration. The mine will disrupt that activity, resulting in
a reduction of habitat.
- All
of the birds will certainly be exposed to increased toxicity if base values
of lead, copper, antimony, and mercury are raised as a result of the mine
activity as they are at the upper level of the food chain.
- These
metals would be incorporated into the plankton and phytoplankton, aquatic
invertebrates such as shrimp, blood worms, mayfly nymphs, etc. that feed
on the plankton and phytoplankton will further concentrate the metals so
that all organisms feeding on these or their adult forms will, over time
continue to concentrate them. It is the DDT problem repeated. A more recent
example of metal poisoning is that derived from exposure to lead shot in
wild fowl. It is the concentration up the food chain that is the danger.
Problems would include: neurological issues, intestinal blockage, genetic
problems for embryos etc.
- The
most seriously affected would be those animals that feed on fish, such as
eagles, ospreys, loons, and mergansers.
- There
are a number of species that use this area as a breeding ground and some
of them, would at least here, be considered rare and threatened. Clark’s
nutcracker, Pileated Woodpecker, Lewis’s Woodpecker, Dusky and Sharp
tailed grouse to name a few.
- There
are red and blue listed birds under Raptors that will be impacted.
3. Health and Safety
- The
increase in Lac Le Jeune Road traffic is a concern. Many Lac Le Jeune
residents commute to Kamloops and use that route because there are infrequent
vehicle accidents and generally winter road conditions are superior to
Highway 5.
- Closure
of Goose Lake Road would reduce exit options during an evacuation.
- An
anticipated concern is the closure of “Lac le Jeune highway” which passes
through the proposed Ajax site. We seek guarantees that Lac Le Jeune road
will remain open as a means of access to Le Jeune. If both Goose Lake Road
and Lac Le Jeune Road are closed, this leaves only one access to Kamloops
and represents potentially a problem with egress in the event of fire in
our area. Clarification of what is to be done with respect to this is
essential.
4. Lifestyle
and Recreation
- Residents
of Lac Le Jeune chose this region because of the peaceful, quiet
environment and the many opportunities to enjoy the outdoors. Lac Le Jeune
Road and Goose Lake Road are popular cycling routes. Many residents enjoy
fishing at Jacko Lake, especially early in the season when Lac Le Jeune is
frozen. We frequently share photos and stories about our many wildlife
encounters. The location of our community is ideal -- a scenic drive to
Kamloops just 30 minutes away, yet we enjoy all the benefits of remote
living.
- We
have concerns for the continued viability of the Jacko Lake fishery. Apart
from the potential for the loss of this fishery due to chemical, particulate,
and sonic causes, we wonder if KGHM Ajax would even permit access to the
lake given its proximity to the active mining site. And, even if access were
permitted, would intermittent closures during periods of blasting
effectively eliminate the lake as the prime, world class fishery it in now?
In
summary, we are not assured that Ajax Mining has undergone adequate research or
considered all potential environmental impacts to claim that the project is
“environmentally responsible”. For example, the environmental report is based
on the best possible outcome from proposed steps to reduce dust. Ajax should
be reporting what the worst possible results from mine operation might be.
Thank
you for taking our concerns and questions into consideration.
Corinne
Schock, President
Lac Le Jeune Conservation Association
