Science Response 2020/052

Assessment of the Ecological Impact of the Grassy Mountain Coal Project on Westslope Cutthroat Trout in the Blairmore and Gold Creek Watersheds, Alberta

Context

The Grassy Mountain Coal Project (the Project) is an open-pit mine proposed along the eastern edge of the Rocky Mountain foothills approximately 200 km south of Calgary, AB, situated in the watersheds of Blairmore Creek (50 km²) and Gold Creek (63 km²) which are major drainages in the Crowsnest River watershed. The Gold Creek watershed contains watercourses identified as Critical Habitat (CH) for 99% genetically pure Westslope Cutthroat Trout (WCT, Saskatchewan-Nelson River Designatable Unit), which are listed as Threatened under the Species at Risk Act (SARA). Blairmore Creek contains watercourses with near-pure WCT populations (95–99%), which are considered areas of high potential to support the recovery of genetically pure WCT (The Alberta Westslope Cutthroat Trout Recovery Team 2013, DFO 2019). A Recovery Strategy and Action Plan (RS-AP) has been prepared and provides both the strategic direction for the recovery of the species, including the population and distribution objectives, and what is required to achieve those objectives (DFO 2019). The RS-AP guides federal and provincial governments to identify, maintain, and improve the distribution of pure populations in the province and to improve awareness of the species for their conservation and re-establish pure populations in sites within the original WCT distribution (DFO 2019).

Benga Mining Limited’s (the Proponent) Environmental Assessment (EA) has projected ecological impacts on pure and near-pure WCT and its habitat, and proposes preliminary mitigation, monitoring, and offsetting options. Fisheries and Oceans Canada (DFO) will be presenting their technical analysis of the Proponent’s Environmental Impact Statement (EIS) at the Joint Review Panel hearing for the EA of the Project. DFO Fish and Fish Habitat Protection Program (FFHPP) and Species at Risk Program (SARP) are concerned that alteration and destruction of habitat in the Gold Creek and Blairmore Creek watersheds will compromise the survival and recovery of Alberta WCT. More specifically, in order to authorize the destruction of CH (i.e., Gold Creek watershed), DFO requires robust scientific evidence that such destruction would not jeopardize the survival or recovery of the species. DFO FFHPP and the SARP are requesting DFO Science to provide science advice on the assessment of effects to WCT, including whether the proposed project impacts, mitigation, and offsetting measures would jeopardize survival or recovery of the species. While section 73 of the SARA preconditions are part of the regulatory phase, the sensitivity of WCT necessitates that DFO provides the Joint Review Panel with advice on the potential risks the Project poses to the survival or recovery of WCT for their consideration.

Based on the EA provided by the Proponent, the objectives of this review are to determine:

1. if there is sufficient information available to assess whether the proposed CH destruction or harmful alteration in Gold Creek would jeopardize the survival or recovery of a) the Gold Creek WCT population, and b) the potential survival or recovery of a near-pure population and/or potential re-establishment of a pure population in Blairmore Creek as per the recovery objectives in the RS-AP;
2. if there are gaps in the proposed monitoring plans to ensure mitigation measures are effective and offsetting is functioning and effective, and if so, how can these gaps be addressed; and,
3. if the proposed draft monitoring plan is sufficient to demonstrate that the offsetting would meet its objective, as well as whether there is any supporting scientific information that demonstrates that offsetting for CH has been effective previously, and if so, whether those conditions met the current proposed offsetting plan (e.g., scope and scale) would effectively replace the lost habitat and populations.

This Science Response Report results from the Science Response Process of October 22, 2020 on Science Advice on Westslope Cutthroat Trout Critical Habitat Destruction and Jeopardy – Grassy Mountain Coal Project.

Science Response 2020/052 (PDF, 1,312 KB)

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