On behalf of the Edmonton Chapter of the Council of Canadians, please accept the following comments about the Proposed Coal Mining Effluent Regulations.
It is imperative for Albertans that the new regulations actually protect our streams and rivers along with aquatic life including for the following reasons.
- Several coal mines are proposed for the Eastern Slopes of the Rocky Mountains
- The headwaters of the major rivers that provide water for the prairie region are located in these areas
- The Government of Alberta has committed to requiring that Alberta coal mines adhere to the new regulations
- Coal mining effluent is already a significant environmental problem in Alberta
There are several flaws in the proposed regulations, particularly in the 2022 version, that put our watersheds and the species that live in them at risk. These include:
- Raised thresholds for Total Suspended Solids (TSS) and selenium compared to the levels in the 2020 version
- Lack of sufficient monitoring of both the amounts of deleterious substances and impacts on species and the environment
- Lack of measurement of impacts on species
- Lack of consideration of cumulative impacts including from multiple mines up and downstream from each other
- Lower standards for existing mines and new mines that begin production within three years of implementation of the regulations
- Lack of effective enforcement and penalties for companies that exceed thresholds
The Edmonton Chapter of the Council of Canadians recommends that the Environment and Climate Change Canada address these issues and revise the regulations so that they will ensure that our water and the species that live in them and use them are adequately protected.
Council of Canadians, Edmonton Chapter