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AWA’s Statement of Concern regarding CST Canada Coal Limited’s mine expansion application

November 21, 2023

On October 10, 2023, CST Canada Coal Limited submitted an application (#1948872) requesting life-of-mine (LOM) pit modifications for their mine license (C2011-8K) to increase their allowable mining depth at the No. 8 Mine near Grande Cache. In the last year, three incidents involving the release of waste into the environment have occurred at CST Canada’s coal mining operations.

The company attributes the latest incident on June 19, 2023, to heavy precipitation and regional flooding, weather events that will only become more common, severe, and unpredictable under future climate predictions. The incidents prior, where over 100,000 litres of coal wash water were released on December 29, 2022, and another 1.1 million litres of coal fines were discharged into the Smoky River on March 4, 2023, occurred during regular operations. Coal wastewater is known to have detrimental effects on fish and aquatic ecosystems within affected waterbodies. Selenium is a common pollutant from coal mining, and if present, can potentially cause deformities and reproductive failure for fish. Pollutants from coal mining can also interrupt seasonal migrations and lead to extirpation of species in affected watersheds.

The frequency of incidents occurring at CST Canada’s mine sites at their current capacity necessitates Alberta Energy Regulator (AER) interrogate whether expanding CTS’s mine license is consistent with AER’s mandate under the Responsible Energy Development Act (REDA). REDA states the regulator must “provide for the efficient, safe, orderly and environmentally responsible development of energy resources and mineral resources in Alberta through the regulator’s regulatory activities” and “monitor and enforce safe and efficient practices in the exploration for and the recovery, storing, processing and transporting of energy resources and mineral resources” (Sections 2(1)(a)), and (2)(f)). It is not environmentally responsible to approve further development of the No.8 Mine until AER can enforce safe and effective practices at CST Canada Coal Limited.

Two investigations by the AER, in which CST allegedly failed to immediately report a release of a substance and did not comply with a term or condition of an approval, are currently ongoing and unresolved.

For these reasons and more, AWA submitted a statement of concern on November 9, 2023, requesting AER complete the outstanding investigations of CST Canada Coal Ltd.’s operations and management before making a decision to amend their mine license. Furthermore, moving forward, AER must carefully consider whether approval of any further coal development in the province is in the public’s best interest and compliant with the purposes of the REDA, Coal Conservation Act, Environmental Protection and Enhancement Act, and Water Act.

Read AWA’s full statement of concern here.

Shortly after our submission, another incident occurred at CST’s coal mining operation; due to wall instabilities, one worker and the excavator they were using were partially buried by falling rubble. While they thankfully walked away unharmed, CST should have to demonstrate they have new standard operating procedures in place that address the root cause of these incidents and prevent their occurrence in the future.

A photo of the dozer partially buried at CST's Grand Cache coal mine following a wall instability and collapse (c/o United Mine Workers/The Canadian Press).

A photo of the dozer partially buried at CST’s Grand Cache coal mine following a wall instability and collapse (c/o United Mine Workers/The Canadian Press).

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