One Project - One Joint Federal/Provincial Environmental Review Process
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The Brokenhead River begins in the wetlands of Sandilands Provincial Forest, located in southeastern Manitoba. It ultimately drains 200 kilometres later into Lake Winnipeg. Most of the river is navigable by canoe or kayak.
This meandering river is now under threat.
It might very well become a toxic dumping ground for CanWhite Sands Corp (CWS) of Alberta. Last month, CWS filed a proposal under Manitoba’s Environment Act, for approval to construct a silica sand processing facility near the town of Vivian. The closing date for commenting on this proposal is Aug. 25.
Once the processing facility receives government approval, CWS intends to submit a second application. This would be for both the mine, where the sand will be obtained, and for the methods the company will use to extract it. The splitting of a single proposed project into two separate ones in this manner probably makes approval a foregone conclusion.
CWS indicates that 15 per cent of what it will extract (from 60 metres below the surface in the Winnipeg Formation aquifer), will be sand and shale. That means that 85 per cent will be water — a fact conveniently ignored in the company application. Simple math shows that in order to produce its intended target of 1.36 million tonnes of sand per year, CWS will also need to extract 7.7.million cubic metres of water annually.
This will surely pose a serious problem for the people of southeastern Manitoba who rely on this aquifer for their drinking water, because this much water coming out of the aquifer annually will certainly inhibit the ability of this aquifer to recharge itself.
Since the average Canadian uses 329 litres of water a day, this means the amount required by the company would serve a city much larger than Brandon each year.
The sand and water will be sucked up to the surface through hundreds of boreholes; only a fraction of it will be needed to process the sand in the wet plant. The bulk of it, likely more than six million cubic metres, will likely be dumped into the Brokenhead. It will contain high levels of heavy metals, chromium, arsenic and neurotoxins. It will also be acidic, as pyrite in the shale will cause acids to drain into the river.
Of course, CWS never mentions any of this in its application. That would apparently be too transparent for them, and might even raise a number of alarm bells.
The release of deleterious substances into the river would be a clear violation of the Federal Fisheries Act and would threaten aquatic life there — life such as the rare chestnut lamprey eel, an at-risk species still surviving in the Brokenhead. It would almost certainly be affected.
The river runs through the Brokenhead First Nation, which, to my knowledge, has never been consulted on the effects of this project on their treaty rights.
What The Frack Manitoba is therefore calling on the appropriate authorities to do the following.
First, request that the province of Manitoba suspend its approval process until such a time that the appropriate federal authorities have the required information from CWS to determine the extent of the adverse impacts the proposed development project will have with respect to federal jurisdiction. And that the proponent (CWS) submit information not only for its proposed silica sand processing facility, but also its silica sand mine and mining method, to be reviewed as one project via a joint federal/provincial panel-review process, to determine the extent of the adverse impacts with respect to federal jurisdiction.
Secondly, we call on the Federal Minister of Environment ad Climate Change to exercise his/her discretionary authority under Section 9(1) and designate the CanWhite proposed silica sand processing facility, its silica sand mine and the mining method used to extract the silica sand a "Physical Activity" under the Impact Assessment Act.
Third, we request that the Crown (federal/provincial, as they are not divisible) undertake a Section 35 consultation process with Brokenhead First Nation to determine what, if any, adverse impacts this project will have with respect to Brokenhead First Nation Section 35 rights prior to any environmental approval of said proposed development project occurs.
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