To Kamloops City Council:
I would like to applaud Coun. Denis Walsh for publicly requesting that an open public meeting be held for SLR’s presentation of their final report to the City; and that residents be afforded an opportunity to ask questions of the findings.
As council will recall, the SLR report investigated an additional 71 questions submitted by Kamloops residents. The resident questions covered a range of environmental, health, operational and socio-economic concerns, and supplemented a list already submitted by City staff in the course of their review (NewsKamloops. 2016). These were further supplemented with council’s concerns and collectively included several specific to the Aberdeen Neighbourhood. Given that a significant portion of SLR’s professional fees were paid for by the citizens of Kamloops I would argue they deserve an opportunity to hear firsthand SLR’s findings and to pose questions.
This is especially important given SLR’s presentation of preliminary findings on March 18, 2016 where the firm highlighted numerous concerns and issues that could have significant and potentially harmful effects on residents of the community. SLR began their presentation by highlighting how impacts should be approached stressing that a precautionary approach should have been consistently taken throughout the application.
Further, SLR pointed out several specific deficiencies in the KGMH Ajax environmental impact studies as they relate to the Aberdeen Neighbourhood, and highlighted how the project places considerable risks on the residents and their property. Specifically, the presentation pointed out that:
- Predictions on the impacts of blasting on the Aberdeen Hills slope stability may not be accurate given the topographic amplifications associated with the terrain.
- That SLR was surprised by the lack of a property value protection program as a mitigation measure. The SLR lead consultant stated at the meeting that in their experience they would have expected the inclusion of a property value protection plan as a mitigation option.
- That with respect to the hydrogeological work submitted, the Aberdeen area was excluded from the Local Study Area and consequently only assessed in the Regional Study Area. The proponent did not simulate areas outside the Local Study Area in their groundwater model and therefore in their opinion has not met the AIR requirements for the Aberdeen Hills area. (SLR. 2016)
More generally, the report highlighted several health and environmental concerns that potentially could impact resident health such as:
- The selection of total or dissolved metal concentrations in ground and surface water cannot be verified and appear to be inconsistent in that total concentrations were used for assessment of the Baseline Case and dissolved concentrations were used for the Future Case.
- Guidance for the selection of the threshold Hazard Quotient (HQ) in the AIR is from Health Canada, which indicates a HQ of 0.2, below which risks are deemed to be negligible. The BC Contaminated Sites Regulation guidance was used, which recommends a HQ threshold of 1.0. This may understate project health risks including cumulative effects.
- The calculation of the Incremental Lifetime Cancer Risk (ILCR) for project-related arsenic in water appears to be missing and results should be added to the ILCR calculated for country foods at the Knutsford locations. The results as presented may underestimate risks.(SLR. 2016)
These, along with numerous other issues and concerns, were outlined.
Given the various serious concerns raised by SLR in their preliminary report to Council, many Kamloops residents will be extremely interested in hearing directly from the SLR consultants on what they have learned from KGMH Ajax since March 2016 and their objective, professional opinion on the potential impacts of the project. I believe taking the time to allow residents to participate in a forum where the report is reviewed and residents can ask questions will contribute to a greater understanding of the overall report findings and the approach taken by the SLR consultants – a report we as the residents of Kamloops paid $200,000 towards.