CIMI and the terrible, horrible, no-good, very bad news for Alberta

In December 2024, the Government of Alberta announced the Coal Industry Modernization Initiative (CIMI) to address the Coal Policy Committee’s recommendations to build a long-term legislative and regulatory framework to guide responsible coal development across the province. While this initiative purports to modernize the coal industry in Alberta to align with the values of Albertans and create environmentally responsible policies, it instead appears to allow coal mining in the eastern slopes in areas that should be protected from coal mining. This fear was confirmed when on January 16th, 2025, the Minister of Energy and Minerals rescinded the coal moratorium that had been in place since 2022, despite assuring Albertans that a new coal policy will be developed by the end of the year, and that future coal development will be guided and regulated by this new policy.

What will and won’t be allowed with these changes?

Of the various types of surface mining techniques possible in the eastern slopes, only mountaintop removal mining (across all of Alberta) and NEW open-pit mining (in the eastern slopes) will be prohibited according to the CIMI. This still leaves the door open for other forms of surface mining, along with underground mining, to move forward in the eastern slopes.

Terminology in mining is complex, with different projects using various, specific techniques. In general, mines will either be surface or underground projects, though some will be a combination of both. Importantly, all coal mining — irrespective of the specific technique employed at any given location — has a detrimental impact on the environment and can result in air and water pollution, and displace other activities such as recreation and agriculture.

There is no evidence to suggest that the impact of surface mining techniques (strip, contour, highwall, auger) can meet acceptable levels of impact to water sources and the environment as a whole. All surface mining techniques require the removal of vegetation, soil, and rocks on top of the coal (referred to as “overburden”), which results in selenium leaching into streams and rivers when the “overburden” is exposed to rain and runoff. The impact is exacerbated by mining within sloped terrain. In addition to this serious water contamination risk, these types of industrial activities destroy habitat and displace wildlife species. They are also incompatible with desirable (and tourism-driving) recreation activities in Alberta’s Rocky Mountains and eastern slopes such as camping, hiking, biking, climbing, and enjoying time on public lands with friends and family.

The Coal Industry Modernization Initiative (CIMI) suggests that new mining proposals will be considered if “best water practices” are implemented. It is unclear what these ‘best water practices’ are. The techniques the Government of Alberta has proposed will not prevent habitat disturbance and will certainly not prevent selenium from entering Alberta’s waterways (though that was suggested in the CIMI announcement). The Government of Alberta has a history of allowing damaging mining practices to take place with the promise of future (largely unproven) technologies that will supposedly reverse this damage. As with oilsands tailings, the technology still does not exist, and the damage to the environment and the pollution of Alberta’s waters continues.

Big, Bad News for the Bighorn Region

Among a list of proposed mines in the eastern slopes, where the coal moratorium has prevented further development, seven occur within the Bighorn or West Country region, west of Rocky Mountain House.

These proposed mines occur within the North Saskatchewan Region, a region that does not currently have a regional plan. For this reason alone, following the clear recommendations of the Coal Policy Committee, new coal development should not be considered in this region. The CIMI, and subsequent removal of the coal moratorium, appear to open the door for these mines to be developed.

• The Blackstone project, owned by Valory Resources Inc., is one such project that is likely to go forward. While it is marketed as an underground mine, according to Valory Resources it will require an initial opencut before underground and highwall mining can begin. Valory Resources, as you may recall, is the company that received ministerial letters of support for coal mining in the eastern slopes before the 1976 Coal Policy was rescinded. Meaning, the project would have been able to move forward but the coal moratorium put in place in late 2020 halted its progress. This new development means that exploration may now resume on the Blackstone Mine site.
• Ram River Coal is another mine project of concern that falls within kilometers of the Ram River, essential habitat for threatened native Bull Trout, and a treasured angling locale.
• Oros coal has proposed projects surrounding Cresent Falls Provincial Park, an icon of the Bighorn Backcountry that recently underwent a year’s long renovation.
• The proposed mine projects threaten the headwaters region of the North Saskatchewan River, an area that provides nearly 90% of the water for the Edmonton Metropolitan region, and millions of people, businesses, and agricultural interests that benefit from the North Saskatchewan River.

A Coal Policy for Alberta

After rescinding the 1976 Coal Development Policy (Coal Policy), a move instigated in response to heavy lobbying by coal companies, and something the majority of Albertans were actively and loudly opposed to, the Government of Alberta formed the 2021 Coal Policy Committee. The goal of the committee was to develop “innovative recommendations needed to complete a responsible, modernized policy for Alberta coal.” While the committee did its work engaging with Albertans AND industry alike, a moratorium was in place preventing any new coal development across the province.

The Coal Policy Commitee’s Final report includes eight principal recommendations with recommended actions, and five associated observations (see here). Though these recommendations are briefly listed in the CIMI announcement, the Government has been very selective in what it has picked out of the final report, and we believe has failed to carry through the primary recommendations that were emphasized in the final report, and represent the views of Albertans.

Land Use Planning

In the Coal Policy Commitee’s Final report, the need for future coal policy and development to fit within the land use planning framework and be subject to Alberta Land Stewardship Act (ALSA) regulations and permitting, is made clear. As is the need for land use planning to have been completed for the regions in which coal mining has been proposed.

There is a very good chance that if you live in Alberta, you have heard about Alberta’s Land Use Planning Framework and the associated Alberta Land Stewardship Act (ALSA). This policy and legislation provide the framework for all stakeholders in a given region to provide input into regional and subregional plans and theoretically ensure that any new developments are fully considered by all stakeholders before going through. The problem is that, despite the framework being around for nearly 20 years, only two of seven regional, and two of eleven sub–regional, plans have so far been developed.

“Accordingly, the committee believes that regional or subregional land use plans must first be completed before any major coal project approvals are considered. Moreover, land use for the development of coal resources should be determined by those regional and subregional plans.” – From p.40 of the Coal Policy Committee Report

Land use planning has not been completed for most areas where coal mining developments have been proposed. Of the four regions that encompass the eastern slopes, and include proposed coal mining projects, only the South Saskatchewan regional plan has been developed. Lifting the moratorium and not committing to completion of land-use plans before new exploration and mines are allowed makes it clear that the recommendations are being ignored.

The current changes to coal management in Alberta are unacceptable. Albertans deserve clean air, water, and healthy landscapes.

In 2022, more than 50 organizations, municipalities, and businesses signed on to A Coal Policy for Alberta – 2022 and Beyond (www.acoalpolicyforalberta.com) based on publicly available feedback submitted to the Coal Policy Committee. It provides a clear path forward to the end of coal in Alberta.

Any new coal policy put forward by the province should contain the following key principles:

• Reinstate the moratorium on ANY new coal mine exploration or development.
• No further coal exploration or development will be permitted on the Eastern Slopes of Alberta, including expansions of existing operations. The new coal policy should cover the entire area previously covered by the 1976 Coal Development Policy and prohibit new exploration and development in this entire area.
• Reclamation of lands disturbed by coal exploration activities with coal exploration permits must be reclaimed by the company no later than December 31, 2025. Reclamation costs should be covered in full by the companies and not fall to the taxpayers
• Existing thermal and metallurgical coal mining operations in this region will be permitted to reach the end of their lives but must meet all provincial and federal guidelines and regulations, including water quality guidelines, for the duration of operations, post-closure and post-reclamation.
• Closure and reclamation of mines no longer in operation should occur as soon as possible. Re-opening of mines in Care and Maintenance should be considered as ‘new mine operation’ and not be permitted.
• Comprehensive land-use planning, including cumulative effects assessment and threshold planning, should be conducted across the Eastern Slopes to address the impacts of all other land-uses and activities in the region as soon as possible. The Land Use Framework contains the tools for Regional Plans and/or subregional plans that take this comprehensive approach.

If you are concerned about the future of coal in Alberta take action now.