In the Information Sheet issued by the Government of Alberta on December 23rd last year, the intentions of the Coal Industry Modernization Initiative (CIMI) were revealed.
What does the Information Sheet say?
The Information Sheet provides broad statements around intended outcomes of the CIMI, namely:
- mountain-top removal mining and open-pit mining will be prohibited in the Eastern Slopes;
- new coal mining proposals must use techniques for best water practices and prevent adding selenium into waterways (i.e. underground mines or mining technologies such as highwall automated underground mining that move minimal amounts of overburden); and
- protections set out in law and in the 1976 Coal Development Policy for national parks, provincial parks, wildland parks, wilderness areas, ecological reserves, and provincial recreation areas will continue.
The Information Sheet also indicates that amendments “will be focused on royalty rates, standards and techniques for coal mining, regulatory certainty for investors and, above all, building confidence among Albertans that our air, land, water, and wildlife will not be sacrificed”. Aside from these broad outcome statements, there is no precise detail as to potential legislative or policy changes that may occur as a result of the CIMI.
What do we recommend?
The ELC’s comments centre on four main issues: prohibitions on mining techniques, the risk of water contamination, the necessity for land-use planning, and the Coal Policy Committee recommendations not being addressed by the CIMI. Briefly, our recommendations are:
- Expand consultation on proposed legislative and policy changes to include ENGOs and other Albertans. The work done by the Coal Policy Committee in 2021 demonstrated that Albertans desire to protect the beauty and ecological importance of the Eastern Slopes, and to protect the headwaters vital to Alberta. Past consultation undertaken by the Coal Policy Committee does not limit or exclude the need for further consultation on specific legislative and policy proposals such as those being considered as part of CIMI.
- There needs to be clarity and specificity as to what type of mining operations, if any, are appropriate in the Eastern Slopes. Vague restrictions or guidelines that do not reflect public concerns around surface disturbance and consequent habitat loss are not sufficient. Furthermore, water is essential for both ecological and human health but is known to be significantly impacted by coal mining activities (see Legacy coal mining impacts downstream ecosystems for decades in the Canadian Rockies (2024) by Cooke, Emerson and Drevnick). Genuine consideration should also be given to the conclusion that the Eastern Slopes is simply not an appropriate place for new coal mining projects.
- The Coal Policy Committee recommended that coal exploration and development should be guided by Alberta Land Stewardship Act (ALSA) regional and subregional plans, and that these plans should be completed before any major coal project approvals are considered. Accordingly, the ELC recommends a renewed commitment to ALSA regional planning that involves the public and Indigenous communities. In addition, there needs to be clear government commitment to considering and implementing all recommendations of the Coal Policy Committee.
Amending existing legislation without public input is not adequate to address Albertans’ concerns with the extensive surface disturbances and water contamination associated with coal development.
For those who are interested, you can download our brief below for additional context and information regarding our comments on coal policy in Alberta.