This is the comment I submitted to the CEAA.  I have posted it here for others to see and use in their own comments to the CEAA or BCEAO.


To Whom it May Concern:

My comments related to the Raven Underground Coal Project and the current state of review into it are as follows, I trust you will take these into serious consideration when making further recommendations to the Company and advising the Minister and your further review processes.

#1:  Public Comments: I request that the CEAA publish all comments it receives during this, and subsequent public comment periods, as soon as possible when it receives the comments.  Comments should appear on the website within 2-3 business days after they are received by the CEAA so that the public can use them to augment their own comments.

#2:  Full Panel review: I request that the CEAA pursue a full panel review of this project. I believe the scale of the project and its potential effect on residents spanning 7 distinct communities (Port Alberni, Parksville, Qualicum Beach, Nanaimo, Courtenay, Campbell River and Gold River) and many more First Nations communities requires the most rigorous of review regimes so that all residents and affected parties can have their concerns heard.

#3:  Lack of Transportation review: There is currently no indication that the CEAA is considering the effect of the transportation of coal on the public spaces, roadways, and environment between the coal mine and its point of export. Speaking specifically of the currently “preferred route” to Port Alberni, due to the volumes involved and the many parks, residential areas, and tourism and business areas that are along the proposed route, I request that the CEAA broaden its scope so as to consider the effects transport by truck or train would have on the most sensitive areas between the mine and its export point.

Regardless of the method of transport chosen the CEAA must determine the risks associated with transporting this product to export.  In the case of Port Alberni, this would include, but not be limited to the effects of increased vehicle emissions, probability and effect of spills, enumeration of sensitive areas such as bridge crossings and streams, effects from coal dust, noise levels in residential, tourist or hospital areas and traffic safety and congestion.

Attached are traffic statistics for Highway 4.  Between 1991 and 2009 (inclusive) over 1000 accidents occured on Highway 4, 21 with fatilities.

The CEAA must also take into consideration other possible routes including using private timberlands roads.

Finally, the CEAA must not be limited by the company in terms of potential export points.  Consideration must be given to Middle Point, Duke Point and Gold River as identified by the Company in its initial Project Description as possibilities.

#4:  Rail must be considered: In terms of volume of clean coal produced and exported, the current plan represents an unprecedented reliance on trucking for this commodity.  The environmental, social and economic costs and benefits greatly favour rail.  As an example, at the annual production of 820,000 to 1.5 million tonnes of coal, transportation by train to Port Alberni would result in a savings in CO2 emissions of between 270,000 and 391,000kg of CO2 per year.  Those savings jump to over 1.8 million tonnes of CO2 for year versus trucking to Gold River.  Other concerns are traffic safety, particulate emissions, noise, congestion and environmental degradation from between 2.2 and 4.1 trucks per hour on public highways versus 1 train per day.  These savings alone should compel the CEAA to force the Proponent to use rail in place of trucking.

Attached you will find a Emissions and Fuel consumption chart detailing these facts.

#5:  Coal Port considerations: The currently proposed port facilities in Port Alberni are not satisfactory in terms of location and proximity to existing tourism, residential and commercial assets.

The following map was compiled in Spring 2010 from public reports shows indications of smell emanating the area of the effluent treatment facilities and estuary and where prevailing winds (blue being southerly) carried that smell.  This should be instructive of the potential wind driven effects of a coal facility.

The proposed facility on Port Alberni Port Authority (PAPA) property are directly adjacent , to the East, residential neighbourhoods, and to the North, tourism, commercial and recreational facilities at the Maritime Discovery Center, boat marina, and Harbour Quay.    Due to the geography of the Alberni Valley, prevailing winds are directly “inshore” up the Alberni Inlet from the South during winter storms and summer afternoon breezes.  Winter storms have reached Storm or Hurricane force (80-120kph in 2006), but commonly reach 50-60kph in winter.  Summer (May to August) afternoon breezes commonly reach 20-30kph on a daily basis.  Conversely, high pressure weather events cause generally light North to North Westerly offshore winds “down” the Inlet.  The most typical events would carry any dust and noise generated by the ongoing operations of the coal port directly to areas north and southeast of the facility with the areas to the North being the most greatly affected.  Supporting data is available at Environment Canada and at

#5:  Better Coal Port Options:

Following are two diagrams showing options more suited to this facility on the Port Alberni waterfront.  Both options would separate the coal facilities from existing tourist, residential and commercial areas and prevailing winds would carry most noise and dust into other industrial areas.

Option A:

On WFP and Catalyst land in the railyard with conveyor around south side of Catalyst property.

The facility would go near where chip pile is or perhaps where the derelict WFP building and lots are.

The existing rail yard could be reconfigured to include the unloading facility.  The facility would be surrounded by industrial land and as far away as possible from residential and business areas.   The ship loading conveyor would use an existing pier out into the Harbour, keeping ships, and coal dust, away from the shore.

Option B:

Old M&B rail siding reactivated to cross Stamp Ave. Facility covered by trees.

This would place the facility on land that is currently for sale by Catalyst Paper and is unused.  The railway would use an old siding that existed in the 1980s, and used to cross Stamp Ave. near the Barclay Hotel.  The right-of-way for the siding still exists near the Barcklay Hotel and along the main E&N line.

The two parallel red lines are where the new track splits into two parallel tracks.  The railway has indicated they would do this to speed the unloading process (2 cars at a time) and cut down the length of land needed.

The conveyor route would also put the ships in the middle of the Harbour away from the shore.

All options considered for the port facility be it Port Alberni, Duke Point, Gold River or elsewhere must also consider the following:

–  the effects of dredging on surrounding ecosystems

the danger from tsunami inundation

the effects of freighters transiting potentially crowded inlet with recreational and commercial boaters and potential grounding.

the effects of truck or train on economic prosperity and development in the region.

#6:  Rail Coal Loading Facility:

The CEAA must taken into consideration specifically if rail is used how the coal would be loaded from the mine site.  Options would include either a long conveyor from the mine site to the Island rail mainline or would require a dedicated rail spur from the mainline into the mine site.

The conveyor route over private timberlands:

The Rail Spur Route following old grades:

Historical rail and coal infrastructure:

#7:  No Rail No Coal petition:

I have personally been gathering signatures for a petition advocating the use of rail for transport if the project is used.  To date I have collected approximately 380 signatures.   I will not be submitting the completed petitions to the CEAA during this public comment period.  However, I wish to make the Environmental Assessment authority aware that the petition is active and growing.  The text of the petition is below.


We, the Undersigned, believe coal from the proposed Raven Coal Mine must be transported by no other means than railroad to its point of export.

We, the Undersigned, encourage consultations to be held between the Compliance Coal Corporation (the Proponent), the Island Corridor Foundation, Southern Rail of Vancouver Island, the Government of BC and other affected parties to rehabilitate and exclusively use the Island Railway to transport coal from the mine production facility to its point of export.

We, the Undersigned, require the Proponent submit a modified Project Description to the BC EAO specifying rail as the sole transportation method for the project.

We, the Undersigned, call on the BC and Federal Environmental Assessment Offices to consider this project unacceptable if exported product is moved by truck due to increased highway congestion, public safety concerns, CO2 and smog emissions, and cost to taxpayers for maintenance of provincial and municipal roadways and to consider the extended environmental, social and economic benefits a revitalized Island Railway would bring to residents and businesses on Vancouver Island.

This completes my submission on the Raven Coal Underground Project.

Thank you for your consideration of these comments.

Chris Alemany

3854 6th Ave

Port Alberni, BC