Northback Holdings Corp. response to AWA statement of concern

November 28, 2023

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• Coal
• Headwaters
• Livingstone-Porcupine
• Native Coldwater Fish
• Rivers

On November 9, 2023, AWA received a letter from the legal counsel of Northback Holdings Corp. in response to our statement of concern regarding their applications to explore the Grassy Mountain coal deposit. Their opening statement is copied below:

“We act on behalf of Northback with respect to the Applications for a coal exploration permit, a deep drilling permit, and a temporary water diversion licence for 1,500 m3 (1.2 acre-feet) respectively. Please see the attached responses from Northback to the concerns you expressed in statement of concern no. #32274 filed with the Alberta Energy Regulator (“AER”).

We reiterate on behalf of Northback that the Applications are in relation to an exploration program and not a mine development. Pursuant to section 31 of the Responsible Energy Development Act, SA 2012, c R-17.3, any potential future application for mine development at the Grassy Mountain site would be subject to mandatory public notice.

The AER has previously determined that applications for localized exploration programs of short duration with adequate mitigation measures are not likely to result in significant adverse effects on the environment.1 Similarly, Northback’s Applications present minimal risks and will not result in significant adverse effects on the environment due to the temporary nature and small scale of the exploration program and the proposed mitigations.

In light of the above, Northback is of the view that the Applications are not likely to directly and adversely affect you, and that to the extent your concerns relate to potential future development of the Grassy Mountain site, the statement of concern is not properly before the AER at this time because it exceeds the scope of the Applications. The AER has the discretionary authority to disregard statements of concern that fail to demonstrate direct and adverse effects arising from the Applications at issue or which are not properly before the AER for any other reason.

We have attached a map prepared by Northback as Appendix 1 to this letter to illustrate the geographic location of the parties who have expressed either support for or concerns about the Applications. As is immediately obvious from the map, the local community overwhelmingly supports the Applications, and a significant number of the parties that filed concerns reside a large distance away from the location of the exploration program. To clarify, the dots on the map representing support petitions include the named parties who signed the Citizens Supportive of Crowsnest Coal’s Petition in Favor of Northback Drilling Program submitted to the AER on October 2, 2023. Northback appreciates the local support, which reflects the significant positive effects of responsible steelmaking coal resource development to the residents of the Crowsnest Pass and neighbouring communities.

We have also attached with the map a few photos and a link to a video of aerial footage from the Grassy Mountain site demonstrating the extensively disturbed and unreclaimed state of the site.

Northback remains committed to conducting its exploration program in an environmentally responsible manner in collaboration with local stakeholders, Indigenous nations, the Alberta Government, and the AER.”

The response can be read in full here.