Letter to Peter Kent, Environmental Minister of Canada from Kamloops Chapter of the Council of Canadians

Posted by Stop Ajax Mine on September 22nd, 2011 10:47am

On behalf of the Kamloops Chapter of the Council of Canadians, Anita Strong has sent the following letter to Peter Kent, the Environmental Minister of Canada. We want to share this letter as an amazing example of what we should be sending to Peter Kent. Please note, however, that should you also send a letter, it does not have to be this thorough and lengthy. 


225-7th Ave.
Kamloops, BC V2C 3S8


Sept. 2, 2011

The Honourable Peter Kent
Minister of the Environment
Member of Parliament for Thornhill (Ontario)
Les Terrasses de la Chaudière
10 Wellington Street, 28th Floor
Gatineau, Quebec K1A 0H3

Hon. Peter Kent:

Re: Request for an Independent Full Panel Review of the Ajax Mine Project, Kamloops, BC

Background information

KGHM Ajax Mining Inc. has proposed a plan for an open-pit copper and gold mine in close proximity to the residences of a significant proportion of the population of the City of Kamloops (population: 86,376: dwellings: 34,163, Statistics Canada, 2006). (Knight Piésold, 2011: 38)

We understand that the proposed open pit mine would eventually cover at least 1,000 hectares. The mine site is approximately 6 km. southeast of the centre of Kamloops and only 1.5 km. south of the Aberdeen neighbourhood. Situated partially within the boundaries of the City, with the remainder in the Thompson Nicola Regional District, the site is 2.5 and 3 km from the two closest elementary schools.

The Project Description states that “the average annual production of the mine is estimated at 106 million pounds of copper and 99,400 ounces of gold in concentrate, based on a conceptual mine plan supplying 21.9 Mt of ore per year (60,000 tonnes per day) to the mill”.  (Knight Piésold, 2011: 10)  

The mining corporation projects that approximately 442 Mt tonnes (Knight Piésold, 2011: 10) of mine rock would be produced during the 23-year project. Our calculations (365 x 23 x 60,000) suggest that closer to 504 Mt would be produced.  Waste rock facilities would comprise a total area of 663 ha. (Knight Piésold, 2011: 10)  A tailings storage facility  of 283 ha. (Knight Piésold, 2011: 10) would be created adjacent to Inks Lake, a location frequented in all seasons by the citizens of Kamloops (especially families) for various recreational activities. The ecosystem would be permanently damaged if tailings are deposited there.

"A number of airborne emissions may result from the Project including: particulate matter (including fugitive dust) from road use, crushing operation, screening, blasting, loading, conveyance, etc., and Green House Gases (CO2, CO, SOX, NOX) from fuel combustion by vehicles and back-up generators."  (Knight Piésold, 2011: 39)

“Heavy metals such as copper, cadmium, lead, chromium, and mercury are known to be persistent and mobile in the environment, and to be potentially toxic to many forms of life.”  (Knight Piésold, 2011: 42)  Strontium and uranium are also found in measurable quantities in this area.

After considering the previous statistics and background material, the Kamloops Chapter of the Council of Canadians has grave concerns about this project and feels that insufficient information has been provided by the proponents to the citizens of Kamloops. We request that an Independent Full Panel Review be undertaken by the Canadian Environmental Assessment Agency for many reasons (some specific to human health such as air, water and noise pollution issues related to the details provided above).  We also believe that the three general principles which are listed below should be major considerations in a review of the proposed project.

The Precautionary Principle

The Council of Canadians recommends that the Precautionary Principle be a major consideration in any assessment by an Independent Review Panel. Principle 15 of the 1992 Rio Declaration on Environmental and Development gives a general description of this principle: “In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.” The “precautionary principle” is recognized by over 20 international treaties and agreements.

The “precautionary principle” outlines several considerations for decisions affecting the environment and human health. International legal expert Jon M. Van Dyke states that this principle “accords respect to ecosystems and living creatures for their own sake, without requiring that they prove themselves to be useful or to have marketplace value. It rejects the idea that risks and costs can be transferred from one region to another, or from this generation to future ones.”  

Water as a Commons and a Public Trust

We request that this principle be considered in any panel review of the Ajax Mine Project. The notion of the commons is an ancient concept. As seen in many traditional societies, the commons is based on the notion that what belonged to one belonged to all. Many indigenous societies to this day cannot conceive of denying a person or a family basic access to food, air, land, water and livelihood. We see the notion of the commons reflected in many modern societies through public education, public health care and social security for all members of the community. Since adopting the Universal Declaration of Human Rights in 1948, governments are obliged to protect the human rights, cultural diversity and food security of their citizens.  There are two streams (Peterson Creek and Cherry Creek) and two lakes (Jacko Lake and Inks lake) in the proposed Ajax mine area that will be irrevocably impacted if this project proceeds.

The Rights of Nature

An important concept to apply to this project is the notion of the rights of nature. In 2008, Ecuador incorporated the rights of nature in their Constitution. The chapter on the rights of nature notes that “ Nature or Pachamama, where life is reproduced and exists, has the right to exist, persist, maintain and regenerate its vital cycles, structure, functions and its processes in evolution.” Article 3 outlines “The State will apply precaution and restriction measures in all the activities that can lead to the extinction of species, the destruction of the ecosystems or the permanent alteration of the natural cycles.”  In the proposed Ajax mine area, there occur individuals of 4 endangered species, 4 threatened species,  and 10 “of special concern” species.

In 2010, 35, 000 people adopted the Declaration on the Rights of Mother Earth at the World People’s Conference on Climate Change and the Rights of Mother Earth, in Bolivia. On April 12, 2011, the Bolivian government submitted the Declaration to the United Nations for consideration. Bolivia also recently passed the world’s first Law of Mother Earth.

Our modern consumer society is having catastrophic effects on our natural environment. Demand for consumer goods is driving the destruction of our natural ecosystems.

In the book The Rights of Nature: The case for a Universal Declaration on the rights of Mother Earth, produced by the Council of Canadians, Global Exchange and Fundacion Pachamama, Maude Barlow notes “Unlimited growth assumes unlimited resources and this is the genesis of the crisis. From fish in the sea, and old growth forests and wetlands, to oil, clean air and water, we are plundering our planet's natural resources. Quite simply, to feed the increasing demands of our consumer-based capitalist system, humans have seen nature as a great resource for our personal convenience and profit, not as a living ecosystem from which all life springs. So we have built our economic and development policies based on a human-centric model and assumed either that nature would never fail to provide or that, where it does fail, technology will save the day.”

Concept of “living well”

Integral to the notion of the rights of nature is the concept of ‘living well.’ Modern societies have reached a point where we destroy our natural environment to produce material goods that we do not need. Rather than live to acquire more material goods, we need to learn to ‘live well.’ “’Living Well’ includes meeting our fundamental needs such as water, sanitation, housing and knowledge and being satisfied with what we have.

We request a report on what the copper and gold from the Ajax Mine will be used for. In determining whether the destruction of irreplaceable grasslands is warranted, we urge that an Independent Full Review Panel examine critically the material goods that will be produced from the ore mined from the proposed Ajax project. As an important step to implement the concepts of the rights of nature and ‘living well,’ we need to examine how we can use already mined materials to meet our needs rather than harming ecosystems to extract unmined materials.

We appreciate you attention to our two requests—that an Independent Full Panel Review be instituted and that the Panel Report include information on the proposed use of any ore extracted during the project.  We understand that the citizens of Marathon, ON, were successful in initiating a Joint Panel Review of the proposed Marathon Mine, and than the Prosperity Lake project in BC was also subject to a rigorous federal review.  We are asking for the same recognition that this is a project of major import to our community.

We note that our participation in the process is not an endorsement of Schedule 2. As part of the Sandy Pond Alliance, the Council of Canadians is working to render illegal the possibility for mining companies to apply for permission to destroy any waterways in Canada under Schedule 2.

Yours sincerely,


Anita Strong and Anne Grube,

On behalf of the Kamloops Chapter of the Council of Canadians

Knight Piésold.  2011 KGHM Ajax Mining Inc. Ajax Project Description.  Vancouver.

cc: Colette Spagnuolo, Panel Manager, Canadian Environmental Assessment Agency
Cathy McLeod, MP
Hon. Terry Lake, Minister of the Environment (BC)
Kevin Krueger, MLA
City of Kamloops


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