Raven Coal Mine AIR document a real red herring

June 23, 2012 – Comox, BC. The BC Shellfish Growers Association (BCSGA) is disappointed that the many recommendations they submitted…

from the draft version of the Application Information Requirements (AIR) by Compliance Coal Corp. for their proposed Raven Coal Mine have been disregarded.

The key points ignored by the proponent that the BCSGA is requesting are:

1. That the baseline survey done in Baynes Sound be conducted by a third party, independent company. In the final draft, the experimental design, lab work and data analysis will be carried out by AMEC, a company that has been working for Compliance Coal Corp. for the duration of the process, who have no experience with the marine environment in Baynes Sound nor the aquaculture industry.

2. That the study areas in Baynes Sound be scientifically defined based on the area hydrology. The marine temporal boundaries have not been updated and should be based on the hydrodynamic study of Baynes Sound which should be completed before the study area and sampling locations are defined.

3. That the economic importance of the shellfish be recognized as a sustainable and commercially viable industry in the region. There is no mention throughout the entire 239 page document that recognizes the economic value of the Baynes Sound shellfish industry which is a long term sustainable industry that produces approximately $28 million of shellfish yearly and employs approximately 600 people from coastal communities.

Although some recommendations and concerns were addressed, the BCSGA feels that, in those instances, the outcome either falls short or was based on political, rather than scientific decisions.

The BCSGA was adamant from the beginning that any data analysis of a baseline monitoring program be done by an independent, third party without any history of working with either Compliance Coal Corp. or AMEC. It is our understanding that no request for proposals to do this work was ever announced. Instead, AMEC chose to ‘award’ a contract to the Centre for Shellfish Research for the simple collection and deployment of shellfish samples at designated sampling sites. The design of this sampling, all lab work and data analysis will be done by AMEC.

This red herring was intended to assuage the shellfish industry but in reality has had the opposite effect and we find this not only insulting but unacceptable. We continue to demand that all baseline study design, lab work and analysis be fairly tendered to an independent, third party company without any prior history of working with either Compliance Coal Corp. or AMEC.

The BCSGA is an industry association that represents about 160 shellfish farmers in BC that produces more than $38 million of sustainably raised shellfish products and employs approximately 1000 rural and coastal residents.

For the full version of the BCSGA assessment of the Final AIR please see attached document entitled BCSGA Raven AIR Brief.

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For more information contact:

Roberta Stevenson, Executive Director

BC Shellfish Growers Association

Roberta (at) bcsga.ca / 250.890.7561

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