While SRRAC has strongly opposed the virtual meeting format the MCM has proposed for today's community meeting, including through formal submissions to the Ministry and in a press release to the media (see article here in the Rossland Telegraph), we strongly believe as many people as possible should attend today and voice our concerns about the project. Zoom meeting link: https://zoom.us/j/99170309579.
Below we have provided a list of key questions and concerns that SRRAC continues to hold in consideration of this project. We encourage our community to review to identify those they feel valuable and relevant to your own concerns.
Questions submitted to MCM for the February 25, 2025 Information Meeting:
1. ASSESSMENT FOR METAL LEACHING AND ACID ROCK DRAINAGE
Given that the BC Joint Application Information Requirements mandates detailed geochemical characterization of ML/ARD potential for all geologic and mining-related material disturbed throughout the mine’s lifecycle—including during construction and post-closure—why is MCM accepting an application for the Record Ridge mine that completely omits sampling from within the proposed open pit? Considering the serious risks of ML/ARD, particularly the potential for leaching hazardous substances into the aquifer that supplies Rossland’s drinking water reservoirs and the water used by Paterson and Big Sheep Creek residents, not to mention downstream into the Columbia River, and given that the application identifies there are heavy metals and acid generating rock present in the resource, will MCM require that WHY conduct a metal leaching and acid rock drainage of material from the actual pit before any permit is issued in order to meet the BC guidelines and adequately understand the long-term impacts of this project? We note that basing analysis on samples from nearby areas that the company expects to be similar is based on assumptions that are not proven, is inadequate, and is not consistent with BC guidelines or best practices.
2. ASBESTOS SAMPLING
BC Joint Application Information Requirement guidelines and industry best practices clearly require site-specific, representative baseline data—yet the proponent has not sampled the highly faulted zones within the proposed pit, where asbestos is most likely to be found. Moreover, relying on adaptive management (dealing with issues as they arise) as a remedial strategy is not acceptable in this context, as such reactive measures cannot adequately prevent the immediate and potentially irreversible harm posed by asbestos exposure. Can you explain why the Ministry is not requiring comprehensive asbestos testing in these critical locations before considering the issuance of a permit? Given there is no proven way to fully prevent fiber release during activities like blasting and crushing—and the prevailing winds blow toward nearby communities, which are well within the range that asbestos fibers can travel—how does the Ministry justify moving forward without complete data from those zones most likely to contain asbestos?
3. TIMING OF PUBLIC MEETING IN THE PROCESS
In our understanding, draft permit recommendations have already been prepared, marking one of the final stages of the permitting process. This would suggest that MCM has moved into these final stages of the permitting process without first holding a meeting to gather public and stakeholder input on this version of the application. How can the public trust a process that seems to disregard the critical role of meaningful stakeholder engagement? Will MCM invalidate, revoke, or withdraw the current draft recommendations to ensure that the unique insights of community members and other stakeholders are fully integrated? Moreover, with all of this suggesting that the upcoming meeting is seen merely a formality by MCM—a token procedure designed simply to fulfill administrative requirements—what assurances can MCM provide that it will change its perspective and genuinely review and address the concerns raised rather than just moving through the steps?
4. ECONOMIC VIABILITY
The arrangement for the sale of ore over this two-year project appears barely profitable once high capital costs are factored in and that the project’s long-term viability hinges on an unproven, billion-dollar serpentinite-to-magnesium extraction process with no successful precedent at a commercial scale. Further to this, a November 4, 2024 letter from a market consultant that was sent to MCM underscores emerging, lower-cost magnesium sources and questions WHY’s inflated market projections. The letter noted magnesium as a major byproduct of lithium mining, which is increasing worldwide. Processes to extract magnesium from seawater are also emerging. Extracting magnesium from serpentinite presents a major challenge. Even a Quebec operation with $145 million in funding that already had 800 million tonnes of finely ground serpentinite byproducts piled up and ready for processing is now bankrupt. We’re unaware of a functioning facility anywhere in the world that successfully produces magnesium from serpentinite. How does the Ministry view this venture as being in the public interest, especially when the proponent has zero experience in mining or processing? Given these market uncertainties, why would the ministry seriously consider granting a permit for a project that seems unlikely to deliver genuine economic benefits? In what sense is it in the public interest to risk ending up with a half-built or bankrupt mine—and all the associated environmental and financial liabilities that taxpayers might ultimately bear?
5. HEXAVALENT CHROMIUM
Based on the Washington State Department of Ecology’s letter to the EAO, which has been provided to MCM, there are serious concerns about the potential for this project to release hexavalent chromium—a dangerous chemical known to cause cancer and other health problems—even at very low levels. An April 2024 report from Azimuth Consulting shows that, even after water treatment, the predicted levels of chromium (and other harmful substances) are more than twice the safe limits set by current guidelines. Given these findings, why is MCM allowing the project to move forward without proper testing and controls for hexavalent chromium? Prior to permit issuance, will MCM require additional testing, such as in-barrel and time series analyses, to determine exactly which forms of chromium are present at the site and how they evolve over time, so that any dangerous contaminants like hexavalent chromium can be properly identified and managed?
6. INADEQUACY OF BASELINE DATA COLLECTION
Baseline data is the information collected about a site, prior to project development. This data is then interpreted in order to develop effects assessment for the project. These assessments are used to determine the significance of anticipated project impacts to the environment and communities which surround it. These findings are also used to develop appropriate management and mitigation strategies to minimize effects. As noted in many of our questions, large gaps exist in the data collected as part of WHY Resources baseline studies. This is data that the proponent has then used to develop important project impact predictions and management strategies. This includes sampling for asbestos and metal leaching and acid rock drainage as detailed above. Another example is the limited number of groundwater wells, and minimal sampling completed in them, in order to assess groundwater contamination and groundwater flows within Rossland’s aquifer. If baseline data collection is inadequate, the effects assessment findings are at minimum inconclusive. Further, the BC Joint Application Information Requirements and its various supporting guidelines give clear requirements for baseline data that do not appear to be met for this project. What improvements is the MCM requiring the proponent to undertake to its baseline data and effects assessments prior to considering issuance of a permit for this project?
7. HUMAN HEALTH RISK ASSESSMENT
BC’s own guidance makes it clear that a comprehensive Human Health Risk Assessment (HHRA) would be warranted for the Record Ridge project because multiple contaminants (asbestos, chromium, nickel, other heavy metals) and exposure pathways exist, and where significant public concern has already been raised. The need for an HHRA was even raised by one of your own provincial reviewers. Can the Ministry explain why it has not mandated an HHRA as part of this permit review process, especially given the province’s own criteria? Will the MCM commit to conducting an HHRA to ensure the health of local communities is protected?
8. WASHINGTON STATE DEPARTMENT OF ECOLOGY LETTER
The Washington State Department of Ecology, which is a highly credible environmental authority just across the border and directly downstream of the project, has formally requested a full Environmental Assessment for the Record Ridge project and raised serious concerns—including fugitive asbestos emissions, chromium contamination, water pollution, and the risk of re-entraining existing soil contaminants into the environment. These are issues that appear to have been completely overlooked by MCM reviewers. If experts in Washington see these risks as grave enough to warrant deeper scrutiny, why isn’t the Ministry demanding the same level of caution here, much closer to the project, in BC? What specific measures will the MCM take to address each of these concerns, and how can you justify proceeding without addressing the serious risks identified by your expert counterparts in Washington state?
9. PART OF A LARGER, REVIEWABLE PROJECT
There is substantial evidence from WHY Resources’ corporate presentations, media releases, technical documents, and statements made by representatives of the company that strongly suggests that this project is part of a much larger project, with some of these sources referring to a project as large as 1 million tonnes per year. Such a project would clearly require environmental assessment. This means that the project constitutes part of a larger, reviewable project—and that it would be unlawful and contrary to the express provisions of Section 6 of the EAA for WHY to ‘construct, operate, modify, dismantle or abandon all or part of the facilities’ of that project, and contrary to Section 8 of the EAA for MCM or any other statutory decision maker to issue approvals for WHY to undertake or construct part of the facilities under the guise of a smaller ‘pilot’ project. Given this, will MCM halt the MDRC process until an environmental assessment certificate has been issued for the larger project that the company has planned?
10. TRANSPORT OF ORE
There seem to be conflicting plans for transporting the ore from Record Ridge. Earlier materials stated that the ore would be trucked to Trimac in Trail, yet members of the community report that Trimac appears unaware of any such arrangement and is reportedly at capacity. More recent plans indicate that the ore will instead be trucked to Northport for rail loading, but the operator of that facility also seems unaware of these plans. This is questionable, given Washington state’s assessment that the ore may contain 5–15% asbestos by volume, potentially preventing its shipment on public roads, railways, or even transloading within the state. Moreover, the October 2023 mine plan proposed shipping the ore to a processing facility in Addy, Washington—a facility that had been shut down for nearly 20 years and was slated for demolition, and which was designed for a completely different type of ore—while the September 2024 amendment now states the ore will be shipped to the Tacoma seaport. Given these discrepancies, can you clarify the current, definitive plan for transporting and processing the ore? Has Washington State issued permits for the shipment of hazardous materials? Additionally, if the processing is to occur outside of Canada or North America, how does the proponent justify claiming that this ore has strategic mineral benefits for our region?
11. ISSUES IDENTIFIED BY SRRAC AND COMMUNITY MEMBERS
Based on our correspondence with the MCM Cranbrook office, it is our understanding many detailed, specific issues raised by NGOs like SRRAC and numerous community members have been lumped into broad, generic categories by the MCM and dismissed as already having been addressed by committee reviewers—when in fact they contain unique, locally specific insights. We have access to the issues raised by committee reviewers through a freedom of information request and can confirm that NGOs and members of the public have raised issues that have not been identified by committee reviewers. Why hasn’t the MCM been tracking and resolving each of these local stakeholder concerns on an individual basis throughout the process? Given that addressing these issues is crucial both technically and for procedural fairness, what commitment will MCM make to ensure that the more than 200 issues identified by NGOs and community members are comprehensively and thoroughly tracked and addressed through to resolution?
12. COMMUNITY ENGAGEMENT
There seems to have been no requirement for the proponent to respond to any community concerns submitted during the May 2024 public engagement period as the September 2024 amendment that followed the public comment period indicated changes had not been made to the application to address these concerns. What is the purpose of the MCM public engagement process if community concerns are invited and then go unaddressed and seemingly unincorporated in the project?
13. NOTIFICATION OF AND CONSULTATION ON PROJECT CHANGES
We are a community who has communicated and demonstrated, through countless submissions to the MCM, the extreme level of concern so many of us hold regarding the impacts of this project on our lives. We are a community that has continuously advocated for an environmental assessment of the project impacts, to ensure we do not suffer undue harm from the effects of this project, as the proponent and its shareholders reap the benefits. There are still members of our community who are just learning, or who have not yet heard, that MCM has decided that the project no longer requires an environmental assessment. Why did the MCM feel that the September 2024 change in the project, which resulted in the MCM supporting the proponents assertions that it no longer required an environmental assessment, was not a significant enough change to warrant public notification and community consultation of the proposed project change? Given that these modifications are significant enough to merit fresh public input, when will MCM convene a new 30-day public comment period for this updated application?
14. MINE DEVELOPMENT REVIEW COMMITTEE MEETING MINUTES
Transparency and robust record keeping are essential for maintaining public trust in the permitting process, especially for projects with significant environmental and public health implications. The Mine Development Review Committee (MDRC) must demonstrate its commitment to openness by thoroughly documenting its discussions and decisions for public review. The Terms of Reference for the MDRC explicitly state that minutes of all meetings would be provided to the public. However, despite multiple requests from SRRAC and members of the public, including submission and payment for a Freedom of Information Request, no minutes have been provided. In fact, we have been informed that no minutes exist for any of the approximately dozen meetings held so far. When will comprehensive minutes be prepared and made available to the public, in accordance with the requirements of the Terms of Reference?
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