Insights on Coal Development from 5 Retired Fish and Wildlife Biologists

January 27, 2025

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• Coal
• Energy
• Grassy Mountain Blog

Prepared by: Lorne Fitch, Jeff Kneteman, Richard Quinlan, Kirby Smith, George Sterling (June 2021)

Read the full report here.

Executive Summary:

As former Provincial Fish and Wildlife biologists with extensive experience with land use, our observations, monitoring and research provide the following conclusions on coal development in the Eastern Slopes of Alberta’s Rockies:

• Despite the scope and scale of coal exploration programs, they are not subject to any appropriate level of impact assessment, or oversight.
• Cumulative effects assessments are not undertaken for coal exploration programs and, when done for coal development, are too narrow in scope to be effective predictors of issues and impacts.
• Coal mining operations in mountain and foothill settings, with steep terrain features are (and will be) subject to repetitive slope, road and settling pond failures, despite the application of engineering solutions. There are a litany of environmental issues and costs as a result.
• There is much reliance on modelling to predict impacts and the outcomes of mitigation strategies. Models commonly best serve to provide a hypothesis to test, but coal interests frequently present models as definitive, particularly with respect to abilities to ameliorate adverse effects. Modelled results are only as good as the data used for input and need to be verified to provide a sense of reality. Case studies (actual monitored results of impact effects and mitigation undertaken) would provide more certainty and aid in decision making.
• Assumptions made by coal mine proponents need to be tested through a synoptic review of other surface coal mines in Alberta and adjacent jurisdictions, but never are.
• There is a tendency for coal mine proponents to avoid answers to some impacts by deferral to some other unstated subsequent plan, action, monitoring, design or concept. It is virtually impossible then, to realistically determine outcomes and consequences of some mine operations and their cumulative impact on fish and wildlife populations, habitats and on native plant communities.
• Uncertainty is used to conclude that precautionary or remedial actions are not required, rather than incorporating it into operational planning, with appropriate references to causes, interrelationships, consequences and areas where extreme caution is required.
• Adaptive management must include a detailed experimental design (not just monitoring) and clearly articulated options to address the outcome of the experiments. Adaptive management employed by industry is commonly just business as usual with some form of monitoring that is not responsive to immediate problems and has little purposeful capability to address solutions.
• Coal exploration and mining negatively impacts fish and wildlife populations and native plant communities. The risks to biodiversity are consistently underestimated, understated and imperfectly assessed.
• Mitigation/compensation actions proposed and undertaken tend to be untested, unproven, unsuitable, theoretical and overly optimistic.
• In most cases, monitoring proposed and undertaken for both coal exploration and development is not rigorous, robust or sensitive enough to detect changes and impacts in a timely manner for correction.
• Before a concern is acknowledged, a standard of evidence that constitutes a catastrophic mortality event is demanded. Adverse influences in ecological systems are typically subclinical (effects occur in concert with other environmental factors) so such alarm bells indicating impacts are rarely acknowledged and acted upon.
• Failure to achieve the stated (or promised) mitigation strategies to reduce and/or compensate for environmental impacts have been repeatedly demonstrated by prosecution under Federal legislation.
• Coal mines entirely remove existing, functional ecosystems replacing them with a completely foreign and poorly understood state. This altered state can have effects on ecosystems, water quality, lands, and fish and wildlife populations tens and possibly a hundred kilometers away from mine sites.
• Response monitoring, using mostly wildlife presence/absence information creates the impression reclaimed mines benefit wildlife, mitigation is appropriate and this rationalizes the initial approval for mine development as well as the development of future mines. Considering composition, seasonality and source, coal mines are a population sink for some species.
• The capability to address changed environmental state is not included in management plans and may never be possible in the case of surface mines in the Eastern Slopes of Alberta’s Rockies.
• Mine-site reclamation, as practiced, replaces intact, functioning and natural ecosystems with ill-adapted ones dominated by non-native plant communities that may need constant tending to persist.
• Government standards, oversight, monitoring and regulatory enforcement are insufficient to validate the promises made prior to mine development by governments and mine proponents for effective, “stringent” environmental protection during and after mine development.
• Legacy issues from coal exploration and development are rarely profiled and any learnings are routinely ignored. Coal mines in the Eastern Slopes are shown to produce significant issues with selenium contamination of receiving waters. The impacts of selenium on the aquatic environment and fish are not trivial. Current treatment methods are at best, concepts, not proven technologies and have not been demonstrated to be workable at mine scales, over lengthy time periods, including beyond the mine life.
• Every independent cumulative effects assessment and associated study indicates that maintaining the status quo in land use (i.e., increasing the footprint) leads to, or has exceeded the thresholds for ecological integrity and resilience. Maintenance of any metric of ecological integrity (i.e., water quality, stream flows, biodiversity) cannot be assured with coal development, on top of timber harvest, petroleum development, and recreation (especially motorized forms).
• The Eastern Slopes of Alberta’s Rockies are not a frontier of unrealized possibilities—instead, they are a busy landscape where expectations already exceed the ability of the landscape to absorb these dreams. There are no longer places in the Eastern Slopes (including current Category 4 lands) where coal development can be safely, effectively and environmentally accommodated.