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Provincial EA

A Critique of the Environmental Review of the Raven Mine

What is Wrong with the Raven Underground Coal Mine Environmental Assessment Process

by Alice de Wolff, Mike Morrell, Patti Willis, 05May2013

Click here to download the PDF


Coal mine application evaluation deadline extended

Michael Briones, Comox Valley Echo, April 23, 2013

Compliance Coal Corporation's 12,000-page document it submitted in its application for an environmental assessment certificate for its proposed Raven underground coal mine was expected to require some hard-core reading.

It turned out to be just that.

NDP pledges more rigorous coal mine review process

Philip Round, Comox Valley Echo, April 12 2013

If the NDP wins a majority in the provincial elections next month, it is promising to toughen up the environmental assessment process for the proposed Raven underground coalmine.

While the party is not committing to oppose the mine outright, it is pledging to set up a Joint Review Panel - what its provincial environment critic Rob Fleming says is "the most rigorous form of environmental assessment we have."

He set out the party's stance during a visit to Courtenay on Tuesday, after suggesting the review currently underway was inadequate for the scope of the project and the risks it posed to the community.

NDP critic, Comox Valley NDP candidate question environment review of proposed coal mine

Scott Stanfield, Comox Valley Record, April 10, 2013

NDP Environment Critic Rob Fleming considers the environmental assessment underway for the proposed Raven coal mine in Baynes Sound as weak and inadequate considering the scope of the project and risks to the community.

Compliance Coal last week submitted its application, which government agencies are reviewing before it goes public. There is opportunity for public comment before the application goes before federal and provincial governments for final approval.

Application/EIS received by EAO

John Snyder, CoalWatch Comox Valley, April 4 2013

The Raven Coal Mine Project Application/EIS document has now been received ( April 4, 2013) by the CEAA/BCEAO and the 30-day screening period has commenced. The CEAA and BCEAO along with the Working Group will now review the document to determine if it's complete. Since the 30-day period deadline falls on a day that is not a regular business day, the deadline day for screening is May 6, 2013.

After this initial screening process is completed and if the Application/EIS is accepted it will be posted on the BCEAO website at: and the formal 180-day Application Review Stage will commence.

Compliance applying for coal mine Environmental Assessment certificate

Scott Stanfield, Comox Valley Record, March 25, 2013

The filing process will be complete when the company delivers its 12,000-plus-page document.Compliance Coal Corporation has begun the provincial application for an Environmental Assessment certificate and the federal Environmental Impact Statement (EIS) for its proposed Raven Underground Coal Mining Project overlooking Baynes Sound.

Compliance Coal president/CEO John Tapics says the certificate is a key approval required for the project. He expects the mine will create about 350 full-time jobs and spinoff jobs in an "area that has had limited new private industry initiatives in the past few years,” he said by e-mail.

The Raven coal deposit covers about 3,100 hectares adjacent to Buckley Bay. The mine is expected to operate about 16 years.

Opposition to the project is widespread.

Opinion BC's Environmental Protection Has Fallen Behind

Jody Roach, The Tyee, March 25 2013

[Up in the Peace River Valley, residents fear lethal sour gas escapes, and call for tougher regulations on the oil and gas industry. On Vancouver Island, Comox Valley residents are concerned that new mines threaten their drinking water, and ask why the law leaves taxpayers with the bill for mine clean-ups. Across B.C., archaic laws contribute to water shortages that threaten both jobs and fish. More than 1,600 species are now "at risk" in B.C. -- without a provincial law to protect them. Likewise, inadequate laws to contain urban sprawl threaten the "natural" B.C. that attracted us here in the first place.

Compliance Energy announces submission of the RAVEN EA Application/EIS

News Release, Compliance Energy Corp., March 21 2013

Compliance Energy has filed an announcement that the Application and Environmental Impact Statement for its proposed Raven Underground Coal project is being submitted as of March 21, 2013.

Under BC legislation, once the submission has been received by the BC Environmental Assessment Office (EAO), and the Canadian Environmental Assessment Agency (CEAA), they have 30 days in which to accept the application, or send it back for revisions. Once accepted by the BC EAO, the project review is officially underway, with a 50 day comment period, and a 180 day review period.

Read the Canada Newswire announcement here.

Consultation but no consensus

John Snyder, Comox Valley Echo, March 19, 2013

Re: "Coal mine requirements are clear enough, says Province" Comox Valley Echo March 15, 2013.

The recent article by Philip Round centers around the letter sent out by Shelley Murphy executive project director at the EAO, in response to views expressed by Courtenay Council to BC Environment Minister Terry Lake, regarding the proposed Raven Coal Mine Project. The article states "she [Ms. Murphy] noted the Working Group, which included technical experts, along with First Nations, had " determined that the language in the AIR would provide sufficient information to adequately assess the potential effects on groundwater and marine environment at Baynes Sound."

B.C. and Canada take next step in One Project, One Environmental Assessment

News Release, BC Government, March 15, 2013

Note: The environmental assessment for the Raven project will be unaffected by this announcement. Nevertheless, this is a significant change in the way that environmental assessments will be done for projects in BC.

The BC Environmental Assessment Office and the Canadian Environmental Assessment Agency have signed a Memorandum of Understanding (MOU) on the substitution of environmental assessments in BC. For more information, please read the MOU and press release.

In addition, the Environmental Assessment Office has submitted requests to conduct substituted environmental assessments on behalf of the federal government for two proposed projects: the Carbon Creek Coal Mine near Hudson’s Hope and the Sukunka Coal Project near Chetwynd.

Coal mine requirements are clear enough, says province

By Philip Round, Comox Valley Echo, March 15, 2013

The provincial government’s Environmental Assessment Office says it is satisfied the promoters of the proposed Raven coal mine have been set clear enough requirements to meet on groundwater issues and the water quality of Baynes Sound.

It's Time to Rewrite BC's Environmental Laws

News Release, Environmental Law Centre, Dec 20, 2012

Today the ELC announced the release of Maintaining SuperNatural BC for Our Children: Selected Law Reform Proposals. This book is a series of 35 short, readable articles – punctuated by photos and cartoons - that describe key environmental law reforms the next provincial government should consider.

Mine project rejection seems strange

Les Leyne, Times Colonist, October 10, 2012

The more you look at the Environment Ministry's handling of the Morrison Mine proposal, the more unusual it gets.

Finally, a mine B.C. Liberals don't like

By Les Leyne, Times Colonist, October 6, 2012

It's a little startling to see the B.C. government say no to a mine, given all the enthusiasm they display for that industry.

Review not adequate

John Snyder, Comox Valley Echo, August 14 2012

Part of the public dialogue surrounding the proposed Raven Coal Mine Project has centered around the need for a thorough and rigorous environmental assessment (EA) review process. The recently released Application Information Requirements/ Environmental Impact Statement Guidelines Document (AIR/EIS) casts serious doubt on the EA process going forward being thorough and adequate.

Expert's Report Critical of Raven Coal Mine Water Studies

Media Release, CoalWatch, July 9, 2012

A report released July 5, 2012, by noted hydrogeologist Dr. Gilles Wendling of GW Solutions, was critical of the proposed hydrogeology and hydrology studies as part of the environmental assessment process for the Raven Coal Mine Project near Fanny Bay, BC.

Government Pushes Raven Coal Mine to Next Stage, Comox Valley Residents Remain Defiant

John Snyder, The Commonsense Canadian, June 28, 2012

The recently released Application Information Requirements/Environmental Impact Statement (AIR/EIS) Guidelines Document on the Raven Underground Coal Mine Project signals the end of the Pre-application Stage of the Environmental Assessment (EA) process and sets the table for the next stage, which is the Application Stage. This AIR/EIS document is partly the culmination of several years of public consultation, which included 3 public meetings and 3 public comment periods, resulting in a near record 5,000 written comments submitted. Over 95% of the written comments expressed concern or opposition to the project.

Raven Coal Mine AIR document a real red herring: BC Shellfish Growers

News Release, BC Shellfish Growers Association, June 23, 2012

The BC Shellfish Growers Association (BCSGA) is disappointed that the many recommendations they submitted from the draft version of the Application Information Requirements (AIR) by Compliance Coal Corp. for their proposed Raven Coal Mine have been disregarded.

Click here to download this news release

Click here to download the AIR brief

CoalWatch slams latest coal mine document

News Release, CoalWatch Comox Valley Society, June 12 2012


The environmental assessment process for the proposed Raven Underground Coal Mine Project has just taken another step. It's a step in the wrong direction, in the view of the CoalWatch Comox Valley Society.

The BC Environmental Assessment Office recently released its 239 page Application Information Requirements/Environmental Impact Statement (AIR/EIS) Guidelines document on the proposed Raven coal mine.

CoalWatch sent the document to its technical advisory group for review, and the initial feedback is that the AIR/EIS is deficient and inadequate.

"It gets a failing grade from our experts," said John Snyder, President of CoalWatch.

Application Information Requirements/Environmental Impact Statement Guidelines

Application Information Requirements/Environmental Impact Statement Guidelines as approved by EAO for Raven Underground Coal Project dated June 2012

Raven Underground Coal Project at the BC EAO

Comments by CoalWatch: The applicant, Compliance Coal Corp. dba Comox Joint Venture, must now complete the Application and the Environmental Impact Statement in compliance with these information requirements and EIS guidelines.

When the Application & EIS are submitted to the EAO, the EAO in consultation with the Working Group have 30 days to review the documents and either return them to the applicant for revision, or accept them for publication.

Once the Application & EIS are accepted by the EAO, the legislated 180 day review period begins. One of the earliest events in the 180 review schedule is a 50 day public comment period.

In Compliance Energy's news release on June 7, CEO John Tapics is quoted as saying that, "Submission of these Applications is expected before year end.”

The case for strong environmental assessment

Calvin Sandborn, Vancouver Sun, June 5, 2012

Those who fail to learn from history are doomed to repeat it. — Winston Churchill

Canadians should worry about Bill C-38 — Ottawa’s bid to gut the Environmental Assessment Act.

B.C. environment minister likes federal plan to let provinces run reviews

By PETER O'NEIL, Vancouver Sun, April 17, 2012

Terry Lake said B.C. should be seen as a trustworthy steward of the environment

OTTAWA --- B.C. Environment Minister Terry Lake enthusiastically embraced the federal government's plan announce Tuesday to let provinces run environmental reviews of natural resource projects, but said Victoria may ask for federal money to handle that new responsibility.

Ottawa to slash environment review role

By Andrew Davidson, CBC News, Apr 17, 2012

Sierra Club says Tories 'abdicating' responsibility to protect environment

The federal government is reducing the number of departments and agencies that can do environmental reviews from 40 to just three to speed up approvals for projects that will bolster Canada's economy, Natural Resources Minister Joe Oliver said today.

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