AWA’s written submission for Summit Coal’s Mine 14 Public Hearing

June 18, 2025

On June 18, 2025, as required of full participants in the Summit Coal Mine 14 public hearing process, AWA filed a written submission detailing our concerns about the application.

The main concerns are summarized below.

  • The lack of an environmental impact assessment for the Project severely limits AER’s ability to assess the application
  • There must be consideration of biodiversity baselines
  • Environmental conditions have changed and human footprint has increased
  • Provincial policy and goals have changed
  • Global conditions and commitments have changed
  • The application’s study areas are inadequate
  • The negative environmental impacts associated with underground coal mines have not been captured
  • The application has failed to consider cumulative effects
  • The application did not include climate change considerations in the project design

AWA’s written submission can be read in full here, along with the expert toxicologist’s report undertaken to support the submission. The accompanying appendices are available here.

Background:

In the subalpine and montane ecosystems of Grande Mountain, Summit Coal Inc. hopes to develop an underground, room-and-pillar style coal mine just over three kilometres northeast of Grande Cache, overlooking the Rocky Mountain hamlet.

The proposed project footprint of Mine 14 overlaps important mountain goat and bighorn sheep habitat, Alberta’s Grande Cache Grizzly Bear Management Area (BMA2), and the Berland and Upper Smoky Caribou Planning Area Regions. The project plans to regularly discharge mine water into tributaries that feed into the source lakes that supply Grande Cache’s drinking water.

The development of Mine 14 has been in limbo for almost two decades, Summit’s last self-imposed hiatus in 2012 due to unfavourable market prices for coal. Renewed pursuit to get the project running only began again in 2021 – 2022 when prices began to rise.

Timeline:

August 25, 2023 – AWA provided a Statement of Concern to the Alberta Energy Regulator on August 25, 2023, requesting them to deny Summit Coal Inc.’s applications under the Water Act and the Environmental Protection and Enhancement Act.

October 5, 2023 – The legal counsel for Summit Coal Inc. sent a letter addressing all the individuals, organizations, and communities who had submitted a statement of concern regarding their proposed Mine 14 expansion.

December 17, 2024 – AWA requested to participate in the AER’s public hearing on applications submitted by Summit Coal Inc. for the Mine 14 Underground Coal Mine Project.

February 7, 2025 – AWA is granted full participation rights in the upcoming public hearing on Summit Coal’s Mine 14 proposal near Grande Cache

February 11, 2025 – Summit Coal Inc. requests the Mine 14 Public Hearing proceedings be postponed to give them “sufficient time to consult with its investors and other key stakeholders”, as the AER’s “decisions have significant implications for the future of the Mine 14 Project”.

February 25, 2025 – Summit’s legal representatives sent a letter to the AER requesting a pre-hearing meeting to determine what they characterize as “substantive issues” with the proceedings. Summit also requested to set a timeline they want AER to abide moving forward, attempted to limit what AWA should be permitted to speak about during the public hearing, and called into question the AER’s decision to include AWA in the proceedings.

March 3, 2025 – The AER promptly responded denying Summit’s requests.

 

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