Letter to the Coal Policy Committee
To: Coal Policy Committee
Thank you for the opportunity to communicate our concerns and views on Alberta’s Coal Policy.
The Alberta Hiking Association
The Alberta Hiking Association ("AHA") is a volunteer organization that was formed in 2008 to be the voice of the hiking community in the province. A recent reliable survey (Alberta Recreation Survey 2017) reveals that over 50% of Alberta’s population, or approximately 2-million people, actively engage in hiking. Hikers are the largest single recreational user group on Alberta’s public lands. The survey results also reveal that about two thirds of this activity occurs in the Eastern Slopes of Alberta which include both parks and non-park public lands. Our comments and concerns focus on this important region.
The Importance of the Eastern Slopes
The Eastern Slopes provide a high degree of public access to high quality scenery and important natural values including critical headwaters of streams and rivers as well as diverse, wild, native plant and animal communities. The high degree of public access to high quality scenic and natural characteristics is crucial to the hiking experiences in this area and the reason it is so popular. It is critical to the large and growing hiking community in Alberta that these important values and opportunities continue to be protected or enhanced. It is the ready access to high quality wild and scenic country that will continue to attract many people to this province to live and visit.
The importance of the Eastern Slopes has been recognized by successive provincial governments. In 1976, the Eastern Slopes Policy was introduced by the provincial government. Under the Eastern Slopes Policy, a form of land use zoning was created to protect areas with high environmental and aesthetic values from incompatible development such as coal mining. For example, in the “Prime Protection” zone, no coal exploration or development was allowed. And in the “Critical Wildlife” and “General Recreation” zones, coal activity would only be allowed “under certain circumstances and under special conditions and controls where necessary”. While the Eastern Slopes Policy did not prohibit coal exploration and development, it did restrict it.
Open Pit Coal Mining is Not Compatible With Non-Motorized Recreational Pursuits Such as Hiking
We know from past and ongoing coal activity in our province and elsewhere that its impacts on air and water quality are real and difficult or impossible to mitigate. Fundamentally, coal activity conflicts with other land uses including outdoor recreation. We have seen recent extensive road building and drilling activities on high ridges north of the Crowsnest Pass which will be difficult or impossible to restore to a natural state. Some of these roads have resulted in nearby traditional public vehicle access to be gated off. Hundreds of thousands of hectares of coal leases have been granted without consultation across the Eastern Slopes in areas of high hiking use from Brule/Hinton, Nordegg/Bighorn and Castle/Livingstone. Coal mining cannot be developed in any of these areas without unacceptable impacts to recreation experiences including direct loss of trails and visual impacts. Impacts of coal mining on native fish and wildlife habitat as well as dust and noise all seriously detract from quality hiking experiences.
The 1976 Coal Policy
The AHA understands that the 1976 Coal Policy also used a type of land use zoning to prohibit or restrict coal mining in areas of high environmental and aesthetic value. It did this by creating four “coal categories”. At its simplest, coal exploration and development was prohibited in Category 1, while in Category 2 some exploration was permitted but surface development (ie, open pit mining) was not, without special dispensation from the government. The AHA believes it is important to quote the definition of Category 2 from the Coal Policy:
[Lands] in which limited exploration is desirable and may be permitted under strict control but in which commercial development by surface mining will not normally be considered at the present time. This category contains lands in the Rocky Mountains and Foothills for which the preferred land or resource use remains to be determined, or areas where infrastructure facilities are generally absent or considered inadequate to support major mining operations. In addition this category contains local areas of high environmental sensitivity in which neither exploration or development activities will be permitted. Underground mining or in-situ operations may be permitted in areas within this category where the surface effects of the operation are deemed to be environmentally acceptable.
In June 2020 the government rescinded the Coal Policy, with the effect that the coal categories were abolished. The government encouraged the leasing and exploration of former Category 2 Lands. While the decision to rescind the Coal Policy has since been reversed, and leasing and exploration of Category 2 Land has been paused, the effects over the Coal Policy rescission can be seen on the landscape, with miles of new exploration roads built on Category 2 lands, which include prime hiking terrain.
The South Saskatchewan Regional Plan
The zoning created in the Eastern Slopes Policy was implemented at the “sub-regional” level through Integrated Resource Plans (IRPs), including the Livingstone-Porcupine Hills IRP (1987), which covers the area from the Crowsnest Pass in the south to the headwaters of the Oldman and Livingstone Rivers in the north. This is an area much used by hikers and many of the proposed new open pit coal mines would be located there. The IRP recognized the existence of the coal categories and stated that any applications for coal exploration and development must be processed in accordance with the Coal Policy.
The Crowsnest Pass and the Eastern Slopes north to the Bow River are now governed by the South Saskatchewan Regional Plan (SSRP). The SSRP is based on and incorporates the principles and directions of the Eastern Slopes Policy and, in fact, replaces it in the South Saskatchewan planning region. Under the SSRP, IRPs remain in effect until they have been reviewed for relevance and incorporated as appropriate under the implementation strategies in the SSRP or a future subregional plan under the SSRP. The Livingston-Porcupine Hills IRP is still in effect.
Livingstone-Porcupine Hills Land Footprint Management Plan (2018)
One new subregional plan made under the SSRP is the Livingstone-Porcupine Hills Land Footprint Management Plan (2018). This plan contemplates that the coal categories would be reviewed and the Coal Policy would be updated, not eliminated.
The Path Forward
The AHA acknowledges that the Coal Policy is now 45 years old. We also note that when it was created in 1976, it expressly stated that surface development (e.g., open pit mining) would “not normally be considered” in Category 2 lands “at the present time”. Accordingly, the AHA agrees that a review of the Coal Policy, and the coal categories specifically, is overdue.
The AHA believes that the Coal Policy should be strengthened, not abolished. It should be strengthened by prohibiting outright any coal exploration or development in Category 2 lands, at the very least. All coal leases that were inappropriately granted after recission of the Coal Policy should also be immediately cancelled. In fact, the AHA believes that other than allowing existing mines to finish their economic lives coal mining should be prohibited anywhere in the Eastern Slopes. As stated above, the AHA believes that coal mining is fundamentally incompatible with the environmental and aesthetic values which make the Eastern Slopes so special and allowing coal mining in these areas will have unacceptable net- negative economic and social impacts through damage to recreation and tourism values.
With regard to the environment, the AHA notes that much more is known today about the impacts of coal mining, including impacts on fisheries and wildlife. The impact of selenium on trout is one example and the disruption of surface development on wildlife corridors is another. With regard to recreation and hiking in particular, we note that the Footprint Management Plan expressly recognizes the continued development of the Great Divide Trail.
Thank you for the opportunity to provide our views on Alberta’s future coal policy. We would welcome the chance to meet with you to expand on the interests of Alberta’s hiking community and discuss any of the above points further.
Chair, Alberta Hiking Association
Cc: AHA Board of Directors