Metallurgical coal development along the Eastern Slopes has been a hot button issue in 2021. In this blog, we provide context about coal development and potential implications for the Red Deer River watershed.
*The RDRWA may edit this post if new information becomes available*
Coal development has emerged as a controversial issue in Alberta, triggered originally by the rescindment of the Coal Policy (1976) in 2020, and later by the growing number of metallurgical coal leases along the Eastern Slopes. Mounting public concern over the potential implications of metallurgical coal mining on the environment, human health, and various economic sectors led the Government of Alberta to reinstate the Coal Policy on February 8th 2021, and to commit to future public consultation on a modernized coal policy.
Many of our community members continue to have questions in the aftermath of all this news. What changes remain in place? Where might metallurgical coal development occur in the watershed, if ever? What plans are underway? In this blog, we take stock of the current state of affairs and provide context for ongoing discussions. We also encourage community members to participate in the Government of Alberta’s public consultation process for a new coal policy, starting March 29th, 2021 (learn more).
Who we are: The Red Deer River Watershed Alliance is a multi-sector, non-partisan, and science-based organization with a vision of a “healthy, dynamic, and sustainable watershed, through the efforts of the entire community”. As one of eleven Watershed Planning and Advisory Council’s in Alberta, our work informs an ongoing dialogue about watershed management in the Red Deer River watershed, and spans areas including watershed planning, engagement with different sectors, policy, education, and more.
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The Oldman Watershed Council – one of our fellow Watershed Planning and Advisory Councils – has written three blogs with useful information about coal and watersheds: Part 1, Part 2, and Part 3. While some of the content is specific to the Oldman watershed, much can be applied to our region. Part 3 is the most recent and addresses common questions since the Government of Alberta reinstated the Coal Policy and committed to public consultation.
What is coal used for?
There are two types of coal: thermal coal, which is used to produce electricity, and metallurgical coal, used to make steel. The Red Deer River watershed includes deposits of both types of coal. This blog will focus on the issue of metallurgical coal mining along the Eastern Slopes of the Rocky Mountains. Steel produced using metallurgical coal is critical for infrastructure and construction projects, with demand rising globally. Coal development can also support local economic development and job creation, which are important considerations for many communities along the eastern slopes.
The Coal Policy and coal categories
The Coal Policy (1976) established four land categories that have guided coal exploration and development in the region for decades. Under this policy, metallurgical coal development is prohibited in Category 1 lands, generally not permitted (with potential exceptions) in Category 2 lands, potentially considered in Category 3 lands, and may be allowed in Category 4 lands. Category 1 lands are considered the most environmentally sensitive, followed by Category 2 lands, and then Categories 3 and 4. Any coal mining project is subject to the regulatory review process.
The map below shows the distribution of these different land categories in the Red Deer River watershed. Category 1 (red) prohibits coal development in the upper headwaters of the watershed near Banff National Park, and there are no Category 4 lands in the watershed. Category 2 lands (blue) stretch across the upper and lower headwaters region of the watershed, while Category 3 (green) lands are potentially open for future metallurgical coal development under the current policy.
Map of coal categories under the Coal Policy (1976): Coal leases (dark grey) along the Eastern Slopes include an area in the Red Deer River watershed on Category 2 lands.
When the Government of Alberta rescinded the Coal Policy in 2020 (which has since been reinstated, pending future consultation), the biggest controversy related to the change in treatment of Category 2 (blue) and Category 3 (green) lands. Historically, these lands have been considered sensitive and surface mining was not generally considered. Rescinding the Coal Policy essentially opened up Category 2 and 3 lands to potential metallurgical coal development. The Category 2 lands span the upper and lower headwaters of the Red Deer River watershed, including the Panther, James, Raven, and Little Red Deer sub-watersheds. The James River sub-watershed, located near Sundre, is the area with the largest potential for activity should the treatment of Category 2 lands change again in a new coal policy.
Coal leases and exploration
Just because land is potentially open for coal development, does not mean coal mining will occur. There is a complex regulatory process that regulates coal mining, at both federal and provincial levels (see AER Manual 020: Coal Development for provincial overview). The first step for any company interested in coal development on public land is to obtain a lease. As of January 26th, 2021, the only metallurgical coal leases in the western Red Deer River watershed are within the James sub-watershed and were obtained by Phalanx Coal Canada Ltd in 2020 on Category 2 lands (see map below). To our knowledge, no coal exploration permit has been granted for these leases, and it is unclear if or when a more formal coal mining project may be proposed. The James River joins the mainstem of the Red Deer River downstream from Sundre, and is considered part of the upper headwaters of the Red Deer River watershed.
Alberta’s Minister of Energy, Sonya Savage, issued a directive to the Alberta Energy Regulator on February 8th, 2021 stating: “From the date of the order making this direction, the AER shall not issue any new approvals for exploration for coal on Category 2 lands.” While Minister Savage stated that no new exploration permits will be allowed on Category 2 lands, all previously approved permits are still in place. To our knowledge, while there is no active exploration underway in the Red Deer River watershed, approved exploration on Category 3 and 4 lands in other watersheds can continue. Any changes in coal exploration status are announced on the AER’s “publication of decision” page, which can be searched using the keywords “coal exploration”.
Map of coal agreements as of December 16th, 2020 within the Red Deer River watershed
Key watershed considerations
The upper and lower headwaters of the Red Deer River watershed are the source waters for the basin. They provide much of the clean, cool, and abundant water that downstream users and ecosystems depend on. Some of the top watershed considerations related to metallurgical coal development in the Red Deer River watershed include:
- Water Quality: One of the main concerns regarding coal mines is the potential for contamination of water sources with selenium, nitrate, or sediment. While mining companies intend to impound wastewater onsite and treat it, experience in British Columbia and other jurisdictions shows that downstream water contamination can occur, with potential implications for aquatic ecosystem health and human health. The Oldman Watershed Council has provided more detail here, and water quality will surely be a major focus of ongoing public discussion.
- Water Quantity: The Red Deer River watershed is the only sub-basin in the larger South Saskatchewan River Basin (SSRB) with room to allocate new surface water licenses (with some exceptions; learn more here). Parts of our watershed are recognized as water short or potentially water short, and climate change may change the timing, duration, and volume of streamflows in the future. Any activity in the upper and lower headwaters must consider the need to maintain and protect downstream water provision. Our watershed is particularly reliant on snowmelt to maintain flows, with very little water generated from glaciers compared to nearby watersheds. It is unclear without more research how coal development across a given area may influence water yield seasonally.
- Source Water Protection: Source water protection is part of a multi-barrier approach to protect the quality and quantity of drinking water sources within watersheds and aquifers. Any discussions regarding coal development should take into account downstream drinking water intakes and groundwater wells, and consider monitoring and treatment infrastructure from source to tap.
- Aquatic, ecosystem health and cumulative effects: Another key consideration from a watershed management perspective is the health of aquatic ecosystems, and the quality of habitat for various species, including species at risk in the Red Deer River watershed like bull trout. The Oldman Watershed Council has also identified habitat loss through deforestation and linear footprint density as other important considerations (see here).
What about land-use planning?
The upper and lower headwaters of the Red Deer River watershed have been the focus of decades of land-use planning in Alberta. This is hardly the first time that Albertans have been challenged by tough conversations about land-use, water, and the balance of development and conservation in the region.
Important planning and policy milestones in the area have included the Coal Policy (1976), the Eastern Slopes Policy (1984), and the Rocky-North Saskatchewan Sub-Regional Integrated Resource Plan (1986), among others. Moving forward, a key uncertainty is the status of the North Saskatchewan Regional Plan. When the Alberta Land-use Framework was released in 2008, it ushered in a new era of collaborative multi-sector land-use planning, with a focus on developing regional plans for seven regions in Alberta. While two regional plans have been completed, five others are in varying stages of development, with no clear sense of timelines. The headwaters of the Red Deer River watershed are located in the North Saskatchewan planning region, however the status of the North Saskatchewan Regional Plan remains unclear. This is important because the majority of the Category 2 and Category 3 lands in the Red Deer River watershed are found within the North Saskatchewan Planning Region (see map).
In 2018, the provincial government led by the NDP proposed creating “Bighorn Country”, an area along the Eastern Slopes that would include a new wildland provincial park, three provincial parks, four public recreation areas, and two public land use zones (PLUZs) west of Rocky Mountain House and Sundre. Some of the same areas covered by that defunct proposal may also be affected by potential changes in the Coal Policy. Understandably, some residents and stakeholders may be experiencing a type of planning “whiplash”, as they consider how changing priorities may affect the balance of development and conservation along the Eastern Slopes. The RDRWA’s statement on the Bighorn Country proposal from 2019 can be found here.
Whatever the path forward is for metallurgical coal development, there remains a critical need for long-range, multi-stakeholder, land-use planning that fully integrates land and water considerations through a watershed lens. Depending on the status of the North Saskatchewan Regional Plan, there may be future opportunities for sub-regional planning and integrated watershed management planning that can support this work in the Red Deer River watershed.
The RDRWA understands that water sits at the heart of many of our most pressing societal challenges – connected to energy, food, economic diversification, health, public safety, and more. In the case of metallurgical coal development, we recognize that this issue is complex, and requires nuanced consideration of social, economic, and environmental factors. While some of the potential liabilities of mining operations are clear, a decision will not be easy, particularly given the state of Alberta’s provincial economy and the need for job creation and revenue generation in local communities.
The RDRWA supports a robust and meaningful consultation process with Albertans, and First Nations, to determine the future of coal mining along the eastern slopes. We encourage community members to participate in the Government of Alberta’s public consultation process for a new coal policy, starting March 29th, 2021 (learn more). Meanwhile, the RDRWA will continue to provide information and act as a resource for partners from across sectors.
Map generated using ArcGis webmap, via Twitter (Robson Fletcher, CBC). Boundary of Red Deer River watershed is the delineation used by the RDRWA (2021).
Parts of this article were adapted from blogs written by the Oldman Watershed Council. Thank-you to the Oldman Watershed Council for sharing this information.
Nigel Bankes (Alberta Law Blog, 2021). What are the implications of reinstating the 1976 Coal Development Policy?