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Environmental assessment of proposed Sukunka coal mine

A B.C. environmental assessment certificate will not be issued to proponent Glencore for the Sukunka Coal Mine Project, primarily because of adverse affects to caribou if the proposed project were to proceed. The project is a proposed open-pit mine and coal processing plant in northeastern B.C. between Chetwynd and Tumbler Ridge.

Environmental assessment process:

The Environmental Assessment Office’s (EAO) environmental assessment began on May 6, 2013, and was referred to provincial and federal ministers for decisions on Oct. 17, 2022. 

The review, led by B.C., involved extensive consultation with technical experts and First Nations, as well as federal and local government agencies. The EAO also hired a third-party caribou expert to verify effects to caribou were appropriately characterized.

Throughout the assessment, the process was suspended three times to allow the proponent to address submissions that needed more information, and to conduct additional studies and engagement to address concerns about impacts on water quality and caribou from the project’s working group members. The working group was made up of technical and policy experts from various regulatory bodies in the federal and provincial governments, as well as First Nations, local governments and the regional health authority. Glencore also requested a timeline suspension to discuss federal and provincial caribou recovery initiatives. This resulted in the assessment timeline being extended by 6.5 years in total.

Project impacts to caribou:

Following substantial discussions between Glencore, provincial and federal caribou experts, participating Treaty 8 Nations and the EAO, the EAO’s conclusions were that even with mitigations, impacts to caribou would be significant if the project were to proceed.

Provincial and federal caribou experts and First Nations raised concerns about the direct habitat removal (125 hectares in high-elevation summer range and winter range) and indirect disturbance (4,186 hectares based on a 4.5-kilometre buffer) to the threatened and red-listed Quintette caribou herd.

Sukunka would be located within an important habitat complex, the Bullmoose-Chamberlain Mountain area, and the existing high levels of cumulative impacts to caribou habitat further increase the area’s importance to the Quintette herd. The displacement from this area would lead to increased rates of predation and less desirable habitat that could jeopardize the recovery of the herd and increase the risk of extirpation, or local extinction.

Project impacts to treaty rights and interests:

The assessment concluded that Treaty 8 Nations’ treaty rights were likely to be impacted by the project, in particular, a moderate to serious impact to the treaty right to hunt caribou and minor to moderate impacts on the treaty rights to fish and gather plants.

As the EAO conducted the environmental assessment to support both provincial and federal decisions, the EAO also considered factors identified within the 2012 Canadian Environmental Assessment Act under federal jurisdiction and determined there would likely be significant impacts to Indigenous Peoples’:

  • health and socio-economic conditions related to the perceived increased human health risk from elevated mercury and selenium concentrations;
  • physical and cultural heritage related to impacts on hunting caribou; and
  • resource harvesting and current use of lands and resources for traditional purposes related to impacts on hunting caribou.

In making their decisions, provincial ministers did not consider these factors, as they apply only within federal legislation.

Consultation with First Nations:

The Sukunka project was proposed within Treaty 8 First Nations’ territory. West Moberly First Nations, Saulteau First Nation and McLeod Lake Indian Band are the Treaty 8 Nations located closest to the proposed project and participated in the review as full members of the project’s Technical Working Group. These Nations (along with Doig River First Nation) also undertook an independent technical review of the application with a third-party consultant, which was included in the assessment. The EAO developed a collaborative relationship and met regularly with the Nations, including co-drafting Part C of the assessment report, (which assesses impacts to their rights).

The remaining B.C. Treaty 8 First Nations, as well as Horse Lake First Nation, Kelly Lake Métis Settlement Society and Métis Nation B.C., received notification of key project milestones.

Public engagement:

The EAO held two open houses and three public comment periods and received 999 comments. Key concerns raised by the public included:

  • effectiveness of water treatment;
  • vegetation (specifically Sukunka Lousewort Bog);
  • soils erosion and loss;
  • water quality (flooding events, risk to water quality, and impacts to First Nations ability to fish);
  • greenhouse gas emissions;
  • employment opportunities and social impacts;
  • caribou (loss of critical habitat, risk of herd extinction and impacts to First Nations);
  • climate change (increased impacts including fires, heat domes, flooding and drought); and
  • impacts to First Nations (exercising Treaty rights to fish and hunt caribou).