The Battle Continues – June 2012

This battle is not over.

Yes, the No Rail No Coal petition has been submitted and heard.  Yes, there has been money committed to upgrade the main part of the rail line.  Yes, there continues to be a lot of concern about transportation of goods on Vancouver Island and by Raven Coal especially.

Unfortunately:  No, Raven Coal has not changed its stance.

Today Compliance Energy CEO John Tapics talked to the Alberni Valley Chamber of Commerce in Port Alberni.  There, he made it clear that trucks are still their only option and they are not considering rail.

However, this is no more true today than it was 2 years ago when these issues first came to the forefront.

Contrary to what Mr. John Tapics is alleged to have said, the BC Environmental Assessment Office has made it very clear in its just-released Application Information Requirements and Environmental Impact Statement (AIR/EIS) Guidelines that Rail is still very much on the table.

It is clear from the Guidelines that the EAO has heard at least some of the concerns presented by this petition, and members of the public.

It is also clear that Raven Coal will have to do a full study of the railway option in order to satisfy these requirements.  That means, in effect, that they still must consider the railway whether they feel it is actually an option or not.

The bottom-line is that WE can still force the company, through the Federal and Provincial Assessment process to recommend that the Raven Project only move ahead if it is transported by rail.   Given the information on this website and elsewhere and combined with the information Raven will be required to provide, I believe we will be able to present a very strong case to the EAO and to the Ministers involved for rail to be used for this mine.

Of course, if rail is used, it will require further investment by the ICF in the railway (through whatever means they have to receive or generate funds)  to open up the line from Parksville to Port Alberni.  This is likely to be on the order of another $15 million. Similar to what is being used to get the mainline running from Courtenay to Victoria.

This fight is not over, we are simply in a different phase.

Here are some key quotes from those documents:

You can see the documents on the BC EAO site here.

PROVINCIAL AND FEDERAL SCOPE INCLUDES RAIL:

Part 1 Page 22: 
“The provincial scope of the proposed Raven Project to be assessed includes
Potential rail spur from the mainline or rail siding along the mainline;” 

Part 1 Page 24:
“The federal scope of the proposed Raven Project considered for the EA consists of on-site and off-site proposed Raven Project components, which includes:

– Transportation of processed coal from mine site to coal storage shed at the Port Alberni Port Facility;” 

FULL STUDY REQUIRED INCLUDING ALTERNATIVES:

Part 1 Page 28:
” Alternatives considered for the proposed Raven Project will include the following:    “

Transporting coal to the proposed Port Alberni Port Facility by truck or by train or by a combination of the two
and route alternatives that include utilizing logging roads from the mine site to Port Alberni, and the proposed Haggard connector connecting Hwy 4 via a new highway route adjacent to Horne Lake;

Part 1 Page 18:
 “The feasibility of transportation alternatives, including: utilizing industrial secondary roads, rail or a combination of the two will be identified and evaluated.”

Part 1 Page 19/20:

“Coal resource extraction and associated activities including maintenance will be described in the Application / EIS. These include:

Coal transportation by truck to the Port Alberni Port Facility (including a description of methods to mitigate fugitive dust emissions, analysis and methods to mitigate anticipated changes to traffic (e.g., type and, volume) on public roads);

Part 1 Page 14:

Alternative routes from Hwy 4 to the port terminal at the Port Alberni Port Authority will be examined and analyzed.”

Part 2 Page 65:
GHG emission calculations will include each proposed Raven Project phase, including transportation of coal to the proposed Port Facility at Port Alberni,”

Part 2 Page 59:

Impact of trucking noise along the critical sections of the transportation ROW and occurring on public roadways in the Port Alberni area will be predicted with a highway noise model.”

Part 2 Page 67:
“A description of background noise levels at the mine site and port facility will be included in the Application / EIS. The worst case scenario will be analyzed for the most critical section of the transportation ROW.”

Part 3 Page 163:
“The assessment of potential transportation effects will include an assessment of the potential for spills and accidents, in terms of both safety and environmental effects. Safety considerations will include the number and characteristics of vehicles, speeds, proximity to existing developments, road crossings, and the condition of intersections with other roads (e.g., site distance, presence of acceleration lanes, existing road capacity). Without limiting the above scope of work, Cathedral Grove and Cameron Lake, two primary areas of concern to the public, will be assessed. The need for winter chain-up areas, both eastbound and westbound, at the base of the “Alberni Summit”, will be assessed. Further, the proponent will assess whether the brake check area at the top of the summit should be lengthened to accommodate the increased truck traffic.”

Part 3 Page 162:
As well, a description of the existing railway infrastructure will be provided. Traffic data as part of the feasibility study will be collected from BC MOTI. At minimum, collected data will include existing traffic and truck volumes for Hwys 19 and 4, and preferred route through Port Alberni. Vehicle accident and injury data will be collected from the Royal Canadian Mounted Police (RCMP).”

HWY 19 ACCESS PERMIT REQUIRED IF NOT BY RAIL

Part 1 Page 32:
“An access permit would be required from the BC Ministry of Transportation and Infrastructure (BC MOTI) to connect to the Inland Island Hwy if existing road access or railway access is not utilized.

ACKNOWLEDGING AND INCORPORATING PUBLIC CONCERNS REQUIRED

Part 1 Page 29:
“The Application / EIS will describe how public and Aboriginal groups’ feedback on alternatives was incorporated throughout the EA process and into the mine design, transportation, port facility and shipping process.”

Part 3 Page 151 (Table):
“Pressure on transport system due to coal hauling, workforce and visitors travel to and from minesite and to and from the Port Facility”


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