Editor:
To the Ministry of Environment, re: Application by Mount Polley Mining Corporation to amend permit 11678, which authorizes discharge of effluent from a copper–gold mine and mill.
Thank you for the opportunity to comment on this application.
I feel it is necessary to review the history of this project in order to place the Aug. 4, 2014 disaster and the current application to continue discharging effluent into Quesnel Lake in the proper context.
I didn’t live in this area at the time this mine was approved so I don’t have any first hand knowledge of what happened.
Fortunately, a submission to the Mount Polley Independent Expert Engineering Investigation and Review Panel by the Environmental Law Center from the University of Victoria includes a comprehensive documentation of the approval of the Mount Polley Mine.
According to this submission, a key issue for the public and First Nations concerning approval of the Mount Polley Mine was impacts to pristine or near pristine water bodies such as Hazeltine Creek, Polley Lake and Quesnel Lake.
This issue was so significant that Imperial Metals agreed there would be no discharges from the tailings pond or pits.
No effluent discharge was a key condition of mine approval and Imperial Metals committed to maximum recycle of tailings and pit water, evaporation enhancing techniques and, if necessary, raising the tailings pond berm height to maintain an allowable freeboard to achieve a negative balance in the tailings pond.
In a letter to local First Nations communities, dated Oct. 13, 1989, the President of Imperial Metals Corp. stated that the mill would operate “within a closed, zero discharge system” and that “zero discharge also applies to tailings supernatant which will be recirculated.”
The current plan to discharge water from the Tailings Storage Facility and Springer pit seems inconsistent with this commitment.
I realize that a water surplus may have been forecast before the mine started operation but I doubt that intentional discharge of effluent into Quesnel Lake was discussed with neighbouring communities at that time.
I can’t help but wonder about the sincerity and/or the feasibility of this commitment to zero discharge.
Any approval of discharge from this mining operation would not be legitimate without support or acceptance by local First Nations and other impacted communities and it is not clear that this general support exists.
It is hard not to be cynical about this current public consultation exercise.
Government approved this discharge on a temporary basis, the infrastructure is in place and it doesn’t appear that the public has been provided with any assessment of alternative water management plans.
I can’t help but wonder whether the decision hasn’t already been made.
I feel strongly that Mount Polley Mines shouldn’t be allowed any additional untreated or partially treated discharges into the environment.
They have used more than their share of the natural environment’s ability to absorb pollution and it would be a travesty if they were permitted to continue adding to the damage!
This mine was approved on the basis of no discharge from tailings ponds or pits.
Using Quesnel Lake to “treat” effluent by dilution is not acceptable. Another important consideration relating to this application is the credibility of the applicant. There was evidence suggesting negligence as a contributing factor to failure of the TSF embankment and there are outstanding investigations.
I think the public is reluctant to share any additional risks with this company and is expecting someone to be held accountable for the existing damage.
Keith Monroe
Williams Lake