February 2, 2012

RE: CEAA Registry Reference # 10-03-54754 – Feedback on proposed BURNCO aggregate mine project

To:  Canadian Environmental Assessment Agency
CC:  BC Ministry of Mines and Energy
BC Ministry of Environment – Air Quality Division
Sunshine Coast Regional District
Islands Trust
Squamish Lillooet Regional District
Sunshine Coast Clean Air Society
Future of Howe Sound Society

The Sea-to-Sky Clean Air Society is a non-profit organization committed to improving air quality within the Howe Sound and Sea-to-Sky airshed. Our members include representatives from seven communities encompassing Howe Sound: Town of Gibsons, Bowen Island Municipality, Village of Lions Bay, Gambier-Keats Islands Trust Committee, District of Squamish, Resort Municipality of Whistler, and the Village of Pemberton. We are the stewards of the community-driven Air Quality Management Plan (AQMP, 2007) out of which two dozen Priority Actions have been identified.

As described below, we have concerns related to BURNCO’s project description related to:

–  Land use rezoning
–  Particulate matter (dust) impacts
–  Off-road and heavy duty vehicle emissions
–  Noise impacts
–  Visual impacts
–  Economic impacts
–  Air quality monitoring and compliance

Our comments are based on a number of Priority Actions that have been identified through the collaborative Air Quality Management Plan process.

The Sea-to-Sky and Howe Sound Air Quality Management Plan

The AQMP is a regional, collaborative, action plan for protecting air quality in the Howe Sound and Sea-to-Sky Airshed. A multi-stakeholder committee, the Sea-to-Sky Air Quality Coordinating Committee (AQCC), which consists of provincial, regional and municipal government representatives of the corridor, transit companies, utility companies and local industry, developed the plan.

The AQMP goals direct our position on the proposed BURNCO mine. These goals are:

  • To address Human Health, we have improved regional air quality so there are substantially fewer incidences of respiratory related medical visits and health care costs.
  • To address Ecosystem Health, we have continued to maximize green space and vegetation in community planning and land development to help maintain healthy air.
  • To address Economic Health, we have a strong and sustainable local economy having a positive impact on air quality.
  • To address Climate Change, we have managed the corridor’s air emission contributions to climate change and its effects.
  • To address Visibility, we have maintained, protected and are improving aesthetic viewscapes and vistas through management of the emissions contributing to poor visibility events.
  • To address Odour, we have controlled the emission of odour causing substances that negatively impact on human, economic and ecosystem health.
  • To demonstrate Leadership, we have showcased our AQMP, partnerships and resulting successes regionally, nationally and internationally, and have maintained the perception of clean, healthy air for which we are recognized.

The AQMP identifies 18 Priority Actions, which are programs, policies, initiatives, and bylaws that can be implemented to manage air quality and greenhouse gas (GHG) emissions in the region. A number of these Priority Actions reflect the need to improve standards and regulations guiding industrial activity in the airshed. Improvements to regional air and water quality resources (such as a return of herring and porpoises to the area) can partly be attributed to best management practices adopted by local industry partners as well as the termination of copper mining activities on the eastern foreshore of Howe Sound.

There are several aspects of BURNCO’s proposed project that are of concern to the Sea-to-Sky Clean Air Society. They include the following impacts:

Land Use Re-Zoning Impacts

The proposed project is to be located on a 70 hectare site on the shores of western Howe Sound within the Sunshine Coast Regional District – Electoral Area F – and is currently zoned for Rural Use (RU2). A dozen residential houses exist nearby alongside McNab Creek. Port Mellon is 7.5 km to the south and dwellings exist on Gambier Island 3 km away across Thornbrough Channel. The proposal will require the property to be rezoned for industrial usage in order to allow aggregate processing and storing activities to occur. We would be concerned that rezoning for industrial use would set precedence for other such activities in this area. We would request that this rezoning application process be made as transparent as possible and that public input be widely sought. The Sea-to-Sky Clean Air Society would not likely support a rezoning application for this site.

Particulate Matter Impacts

Particulate matter (PM) is the term for particles found in the air, including dust, dirt, soot, smoke, and liquid droplets. It is most often characterized by particle size: PM less than 10 micrometres in diameter (PM10) and PM less than 2.5 micrometres in diameter (PM2.5).  PM contributes to poor air quality which can negatively affect human and environmental health, as well as visibility. Nationally, the Canada-wide Standard for PM is often used to assess air quality and ensure all communities in Canada meet a minimum standard of air quality, while B.C. has established Ambient Air Quality Objectives (AAQO) for both PM10 and PM2.5. Health Reference Levels (HRL’s) reflect the lowest concentration at which a health impact can be statistically determined. However, health researchers caution that they have been unable to determine a safe level (threshold level, below which there are no effects) for PM. Data from continuous monitoring stations in the Howe Sound and Sea-to-Sky airshed indicates that there were 20 days on which the HRL for PM10 was exceeded in 2010 and 8 days on which the HRL for PM2.5 was exceeded in 2010.

The BURNCO project description notes that atmospheric contamination will be minimized through extraction of the aggregate under wet conditions using a clamshell dredge and that processing facilities will be fully enclosed and operated under wet conditions to limit dust. It is unclear how these proposed mitigation activities will be monitored and/or enforced. We are particularly concerned about PM emissions during the drier summer months and note that certain activities, such as transporting the aggregate to barges and loading them for transportation, will likely incur a significant amount of dust. We are also concerned about the air quality of nearby residential areas, as noted above.

Off Road and Heavy Duty Diesel Emissions

While the project description includes discussion of using electric motors whenever possible, we expect that diesel-based off-road vehicles, heavy-duty equipment, and generators will likely be required. Emissions from these types of engines present both greenhouse gas and particulate matter concerns. The movement of air tends to push these emissions northward up Howe Sound towards the neck of the sound at the community of Squamish and therefore we are concerned about the air quality impacts on nearby residents. Routine monitoring of emissions from the proposed site should be included in the BURNCO plan.

Noise Impacts

Noise from equipment, vehicles, and barge loading will be challenging to minimize. It is not known if the shockwaves resulting from digging activity will permeate within the water column of Howe Sound and affect the communication patterns of marine life such as whales and dolphins, which are beginning to return to the area. Noise travels easily through air across water and therefore residents of Port Mellon, Thornbrough Channel, and Gambier Island could also be affected. It is unclear under which regulation(s) a noise-related impact would fall and therefore which jurisdiction would be charged with enforcing noise issues and deal with any noise complaints.

Visual Impacts

Howe Sound is used recreationally by boaters and the subject area might be visible from the Sea-to-Sky Highway (HWY 99). The visual impacts of a mining operation will be significant. The applicants should be required to maintain a vegetation buffer/screen to mitigate the visual impact.

Economic Impacts

It is important to note that the local economic viability of many of the communities located within the Howe Sound area (Sunshine Coast Regional District, Gambier/Keats Local Trust Area, and Squamish Lillooet Regional District) are reliant upon a pristine ecological setting in order to promote both front country and back country tourism activities. Based on the Natural Step and smart growth principles, this is a purposeful move away from large-scale industrial economic investments towards a more ecologically sustainable jobs and tax base. As noted in the Sea-to-Sky Air Quality Management Plan, any threats to the quality of air in the region are also threats to the local economies of all communities within the Howe Sound airshed.

Monitoring and Compliance

The proponent proposes to use a 300 m wide vegetative buffer between the project site and the marine shoreline to avoid and limit potential visual, noise, dust and emission impacts on the environment. The Sea-to-Sky Clean Air Society is concerned that this buffer and other proposed mitigation measures will be insufficient in protecting the quality of air for nearby residents. A contingency plan should be developed in the case that mitigation practices do not adequately minimize noise, dust, and emissions – such that additional measures and solutions can be easily put into practice if required. A base level of emissions modelling should be performed in order to assess emissions and potential impacts to air quality. Furthermore, the need for ongoing air quality monitoring at regular intervals, by an objective third party, should be included in the long term operational plan of the proposed mine. This data should be made public.

Due to the concerns outlined in the letter above, the Sea-to-Sky Clean Air Society does not support the proposed BURNCO aggregate mine project at this time.