Monday, April 11, 2016

LLJCA Public Comment: KGHM Ajax Application


 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. 

  1. Pollution and Environmental Disasters
  2. Fish and Wildlife
  3. Health and Safety
  4. 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


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