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Synopsis of Comments Received on Draft AIR

Extract, BC EAO & CEAA, October 13, 2011

Please note: this is NOT the tracking table. That will be released in "fall of 2011." It is a "synopsis" of topics in the comments. It also addresses requests to cancel the EA and reject the project, requests for a panel review, and requests to consider carbon emissions from combustion of the coal.

Proposed Raven Underground Coal Mine

Synopsis of Comments Received During the Public Comment Period on the Draft Application Information Requirements/Environmental Impact Statement Guidelines

Approximately 3,000 public submissions were received, with many individuals providing multiple submissions. Over 5,000 comments were received, as one submission may contain numerous comments. The concerns most frequently raised included:

  • highway congestion and accidents;
  • noise from truck traffic and mine operations;
  • coal dust from mine, trucks, and port facilities;
  • greenhouse gas emissions from coal mining;
  • global climate change impacts from coal use;
  • effects of coal washing, water use, and disposal of water;
  • acid rock drainage and heavy metal leaching;
  • contamination of watersheds;
  • effects on Baynes Sound;
  • contamination of shellfish and effects on aquaculture;
  • incomplete aquifer mapping and groundwater/drinking water contamination;
  • tailings pond leaching or excess runoff;
  • effects on wildlife and conservation areas;
  • effects on birds and important bird areas;
  • changes in jobs or employment;
  • reduction in tourism due to the mine;
  • light pollution from mine site;
  • inclusion of Bear and Anderson Lake properties in the environmental
  • inadequate consultation process;
  • effects of natural disasters (including earthquakes and tsunamis) on the mine and port facilities;
  • insufficient bond or liability fund for reclamation; and,
  • environmental management at reclamation and closure.

Comments that were submitted as part of this public comment period are considered public and have been posted to the EAO’s electronic project information centre (ePIC)
( The comments have also become part of the Agency’s Registry project file for the proposed Project, which is available upon request.

The EAO and the Agency note that the majority of public comments submitted were in opposition to the proposed Project. However, it is important to recognize that the objective of the public comment period was to receive input on the information requirements. The EAO and the Agency will carefully consider all of the relevant issues raised, regardless of the number of times they were submitted.

Comments suggesting the rejection of the proposed Project and cancellation of the environmental assessment

Under federal and provincial legislation, proponents have the right to submit a proposal for review. Due process and fairness requires that governments consider and assess the proposal before making a determination.

Comments requesting a referral of the proposed Project to a joint federal/provincial review panel

For the proposed Project, the Executive Director [of the BC EAO] has decided that he will not make such a referral [to the Minister for referral to a panel]

The Agency [CEAA] is confident that the cooperative comprehensive study will be able to identify, analyze, and address the potential environmental effects of the proposed Project [and consequently will not recommend to the Minister that a panel review is warranted]

Public comments regarding greenhouse gas contribution of coal consumption overseas

By current international GHG accounting standards, countries are responsible for emissions that occur within their boundaries. As a result, the cooperative environmental assessment of the proposed Project will examine the GHG emissions associated with the mining and transportation of the coal by truck to Port Alberni, and by ship to the Cape Beale Pilotage Station. The cooperative environmental assessment will not consider overseas GHG emissions as a result of combustion of the coal.

Next steps

Once the proponent responds to the public comments submitted on the information requirements, the EAO will provide the public with an opportunity to comment on the proponent’s responses.

After this public comment opportunity, the EAO and the Agency will then review the proponent’s responses and any public comments received on those responses, make any changes to the information requirements that the EAO and the Agency deem necessary and issue the information requirements to the proponent. The proponent must collect the information and undertake the analyses outlined in the information requirements and provide it to the Agency and the EAO in an official submission referred to provincially as an Application for an Environmental Assessment Certificate and federally as an Environmental Impact Statement.

The Agency and EAO Web sites provide information on the status of the proposed Project and the environmental assessment process and can be visited at and respectively. The public can also stay up-to-date on major milestones by signing up for the EAO's Really Simple Syndication (RSS) feed or the Agency email list. Setup information for RSS is available on the EAO’s Web site; subscribing to the email list can be done by writing to

Click here to download the complete Synopsis document