April 28, 2021

Honorable Jonathan Wilkinson
Minister of the Environment and Climate Change
Office of the Prime Minister
80 Wellington Street
Ottawa, ON K1A 0A2

The Alberta Hiking Association was formed in 2008 and represents approximately 20 hiking clubs from across Alberta. The number of proposed coal mine projects near the Crowsnest Pass and the likely resulting environmental, social and economic impacts are causing increasing concerns among our members and the public at large. The recreation and tourism potential of the Crowsnest Pass is provincially significant and would be seriously impacted by the approval of up to 5 proposed mines in this vicinity.

We have recently learned that Montem Resources proposes to reopen an open pit coal mine at Tent Mountain approximately 10 km southwest of Coleman. The Tent Mountain project is currently undergoing a provincial environmental assessment in Alberta, by the Alberta Energy Regulator (AER). We understand that a federal environmental assessment is not required under the Impact Assessment Act of Canada because the production capacity of the proposed mine is less than 5,000 tonnes/day. Apart from the fact that the capacity is 4,925 tonnes/day, barely under the federal threshold, we also
understand that you may order a federal environment assessment anyway, if in your opinion the coal mine may cause adverse effects within federal jurisdiction or adverse direct or incidental effects, or public concerns related to those effects warrant it.

As you may know, Tent Mountain is located on the Great Divide, the provincial boundary between Alberta and British Columbia. Clearly, Montem’s proposed project will have inter-provincial effects and thus engage federal interests. Not only that, but there is also another existing coal operation by a different company on the same mountain and in the same formation as Montem’s proposed project. In other words, in addition to the two projects being in different provinces, they appear to both be targeting the same coal deposit. It is logical that the volumes of coal removed from Montem’s proposed Tent Mountain project should be considered cumulatively with the existing operation in B.C., thus triggering a review under IAAC. We would very much support the broader and deeper review that the project would then receive.

While we share the larger environmental, social, and economic concerns about coal mines with many other Albertans, our Association has several specific concerns related to potential direct and indirect impacts that the Montem project would have on hiking opportunities in this vicinity.

Firstly, Tent Mountain is only a few kilometers from the Castle Wildland Provincial Park. In fact, the access road that leads to Tent Mountain provides access to the trailhead for the popular Ptolemy Creek Trail, Ptolemy Pass Trail and the Island Ridge trail nearby. We are very concerned that increased mine traffic on the access road will likely directly and adversely impact the current public recreational use of this road as well as the trailhead parking for these hikes. Existing parking areas may be affected and become unusable because of increased industrial traffic.

Secondly, the view of and noise and dust associated with this mine may also negatively affect hikes on other nearby ridges especially Mt. Tecumseh and Crowsnest Mountain. The net result of this would be a loss to the local community and likely fewer hiking visitors coming to the Crowsnest Pass, thereby diminishing potential tourism benefits. For the above reasons, we request that you exercise your discretion to order a review of the Montem proposal under IAAC to ensure that our recreational and tourism concerns along with all the many others are addressed satisfactorily in a Joint Review Panel
process. Thank you for your consideration of our request.

Murray Fierheller, Chair
Alberta Hiking Association
50 50251 Range Road 234 Leduc County, Alberta T4X 0L6
e-mail info@abhiking.ca

Cc: Impact Assessment Agency of Canada
Canada Place
9700 Jasper Ave. Ste. 1145
Edmonton, AB