Lac Du Bois Grasslands Protected Area Near the proposed Ajax Mine Location, British Columbia Phtograph Attribution: By tuchodi - https://www.flickr.com/photos/tuchodi/4043429977/, CC BY
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Re: British Columbia, Canada: Ajax Mine Project Joint Federal Comprehensive Study/Provincial Assessment Report issued by the Canadian Environmental Assessment Agency and British Columbia Environmental Assessment Office dated August 2017, comments due October 10.
Tracy James
British Columbia Environmental Assessment Office
Dear Ms. James:
Environmental Review, Inc. has reviewed the Ajax Mine Project Joint Federal Comprehensive Study/Provincial Assessment Report issued by the Canadian Environmental Assessment Agency and British Columbia Environmental Assessment Office dated August 2017. We have the following comments:
1) In the Executive Summary page iii paragraph 4 the statement is made that the comprehensive study for Ajax Mine is being carried out under the Canadian Environmental Assessment Act of 1992. Since that act was updated in 2012 why aren't the more current requirements being followed?
2) It was not mentioned that the mine will be very close to the protection area: Lac Du Bois Grasslands Protected Area; shouldn't that be discussed?
3) The baseline discussion failed to include a list of previous studies conducted within the project footprint; shouldn't that be added?
4) The baseline discussion failed describe the level of effort of baseline studies (e.g. Number of groundwater monitoring wells, number of surface water sample locations, number of seasons sampled, numbers of chemical and biological parameters analyzed, analytical methods, data quality assurance and quality control protocol); shouldn't that be added?
5) A list of references supporting the claims made was not included; add that (sources of data supporting the conclusions claimed).
6) The proposed Pebble Project in Alaska has spent 7 years and $150 million on environmental and cultural baseline studies. This level of effort is considered reasonable for a project of this size to achieve 'good science'. Although the proposed Ajax Mine will process one-third the daily ore throughput of the Pebble mine (65,000 tons per day (tpd) versus ~200,000 tpd), one would think that the baseline study level of effort for a project of Ajax's size would be more robust. In other words, the assessed effects/impacts and mitigation presented in the report does not meet the generally accepted practice of 'good science'. Therefore the agencies having authority over this project should not approve it since the environmental assessment is insufficient.
7) The associated Conditions document states that several studies will be conducted after approval of the current document. Those studies should be completed and included in this document.
8) Schedule B “Table of Conditions” lists a large number of environmental activities associated with the project, the completion of which are deferred to a later date. For example:
Condition 18. Noise Management and Monitoring Plan
Condition 19. Vibration Management and Monitoring Plan
Condition 20. Air Quality Management Plan
Condition 21. Surface Water Quality Management Plan
Condition 22. Groundwater Investigation Plan
Since these Plans are germane to whether or not the current document should be approved, this document should not be approved until all associated Plans are completed. The current approach of defining conditions amounts to “piecemealing” which sidesteps evaluation of the cumulative impacts of the overall project. Therefore this document should not be approved.
9) The alternative means evaluation focused on alternatives for completing project subtasks (e.g. general site arrangement, tailings storage facility location, water use and supply…) rather than alternatives to the project itself (e.g. no action alternative and subsurface mining alternative). Shouldn’t there also be an alternate evaluation for the project itself?
10) Is there a financial assurance requirement for this project? For example, if there are cost overruns in any phase or during post-closure how will that be handled? Will this project have a financial assurance instrument in place to ensure that long-term monitoring is conducted after the mining operations cease?
When a response to comments is available please sent those to me via email at This email address is being protected from spambots. You need JavaScript enabled to view it..
Sincerely yours, Gabrielli Vargas-Project Manager (Associate in British Columbia), Environmental Review, Inc. (a 501(c)(3) Nonprofit Public Benefit Corporation), 1792 Rogers Avenue, San Jose, California 95112, http://www.envreview.org/