Open letter to Energy, Mines and Resources Minister Brad Cathers:
Alexco Keno Hill Mining Corp. has proposed to take its advanced underground exploration project at the historic Bellekeno mine into production.
The proposal includes details on principal mine development activities involving continued underground development and operations at Bellekeno, and construction and operation of a conventional flotation mill at the Flame and Moth site less than one kilometre southeast of Keno City for the processing and production of minerals from Bellekeno mine.
This project has undergone an environmental review pursuant to the YESSA.
On June 15, the YESAB issued a recommendation document entitled: Type A Water Licence and Quartz Mining Licence Applications - Bellekeno Mine Development. This document recommends project approval subject to a series of specified terms and conditions.
One of the conditions specified in the recommendation document (page vi, condition 30) requires Alexco Resources “to assess the effects of the project on local groundwater supplies.”
This condition reads, in part:
“30. It will be necessary to begin, as soon as feasible (but prior to project construction and operation), baseline characterization of any groundwater resources that will be affected by the project site. This must include an evaluation of:
“Â¥ Groundwater quality and quantity in the area
“Â¥ Groundwater flow rates and directions”
A further condition (page vi, condition 31) stipulates:
“31. Additional ongoing monitoring during operations will be required to determine:
“Â¥ The effects of operations on groundwater resources in the area.
“Since historical baseline groundwater data are limited, establishing an ongoing groundwater monitoring strategy, which is scoped with on-going surface water monitoring programs, is required to assess overall project effects on local groundwater resources. This detailed information on current groundwater conditions will inform the final decisions on post-closure remediation activities at the site’s adits.”
We would argue that if the Yukon territorial government were to approve this project subject to these conditions it would be approving the project in an information vacuum: without information that is vital to determining the impact of the project on Yukon’s precious groundwater (and by default surface water, as many surface waters are fed by groundwater) resources.
One has to wonder why, if after taking control of these operations and discovering years and years of data (by its own admission Alexco Resources claims to have access to approximately 35,000 historical documents and a 300-gigabyte digital database/library of geologic information - much of this information was left behind by the previous owners) there is little to no information about groundwater in the proposed project area. One also has to ask why, if this information was lacking, Alexco did not endeavour to gather this information prior to proposing to reactivate mines in the area and prior to undergoing environmental review of the project.
It seems they don’t even have good climate or water flow data for this project because the recommendations document stipulates:
“34. Complete water balance for the site must be developed and be continued throughout operations.
“35. Minimum and maximum flows for both wet and dry years must be annually re-assessed to assist planning the water extraction adaptive measures.
“36. Characterize the local climate conditions and climate variability with locally derived and recent climate data…
“38. Prepare a detailed quality assurance/quality control plan as part of the overall waste rock
“Management Plan stipulates regular and frequent checks (including lab and field-screening techniques) that will yield a high confidence for waste rock classification.”
Under Health and Safety:
“65. Conduct a noise impact study prior to project implementation.
“66. Develop a noise abatement and management plan based on the results of the noise impact study É.”
They don’t even know if the roads and bridges will bear the weight of trucks!
We are writing to ask that you do not approve this project as recommended by the YESAB until the proponent has gathered sufficient information to adequately assess the potential impacts of this project on the groundwater resources in the immediate project area prior to commencing their mining operations. This is the only way to ensure that our precious groundwater resources are protected.
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James Milley
Keno City Advisory Council
with assistance from John Werring David Suzuki Foundation