British Columbia Mine Reclamation Symposia

Moving goalposts : perceptions of the coal development guidelines 2010

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Proceedings of the 7th Annual British Columbia Mine Reclamation Symposium in Victoria, BC, 1983. The Technical and Research Committee on Reclamation           MOVING GOALPOSTS: PERCEPTIONS OF THE COAL DEVELOPMENT GUIDELINES Paper presented by Margaret Gibson Resource Management Science University of British Columbia Proceedings of the 7th Annual British Columbia Mine Reclamation Symposium in Victoria, BC, 1983. The Technical and Research Committee on Reclamation MOVING GOALPOSTS: PERCEPTIONS OF THE COAL DEVELOPMENT GUIDELINES Out of the many hours of interviews, I conducted for my thesis at UBC in May and June, 1982, several observations reoccurred. One phrase stands out - perhaps not as the single most important view of the coal development guidelines (CDG) - but certainly as a pervasive one. That was, "that the Goalposts Keep Moving". This metaphor, where the "game" to develop a new coal mine has become increasingly difficult, indicates not only that the rules are changing but that the size of the whole field has expanded. This observation of frustration was and is constantly expressed, not only by the representatives within the coal industry but by consultants and by numerous individuals within government agencies. It is my hope that through a presentation of an additional analogy again from football, I might bring some clarity to the dimensions of this frustration. I would like to suggest the advantages of a different attitude and some strategies that might, given the evolving nature of the game, prove helpful. The beginning of the 1900's witnessed twenty years of controversy and two crises which almost proved fatal to the game of football. Calls for abolishment of the game came from educators, legislators and journalists. "The President of the United States even threatened to ban the sport". (Moore, 1967)  Football at this time was a ground game characterized by mass plays like the infamous flying wedge of Walter Camp's Yale team. (Camp was well known and revered as the father of American football and founder of the "All Stars" concept). The risks in football were very real. They were reflected by an appalling number of deaths and injuries caused by the brutal tackles and pile-ups. A spectrum of debate existed around the issue. Outraged denunciators claimed that football was "boy-killing, education-prostituting, gladitorial [sic] sport" (Mathews, 1905; in Moore, 1967) and demanded that it should be abolished. The attitude of the middle ground was one that advocated rule changes and reform. The other extreme, Walter Camp's position, while acknowledging the concerns, fought valiantly to retain the old style of play and rules. 107 Proceedings of the 7th Annual British Columbia Mine Reclamation Symposium in Victoria, BC, 1983. The Technical and Research Committee on Reclamation The season of 1904 saw 21 deaths and 200 injuries. This was followed in 1905 with a season beginning in an apparently similar pattern. A crisis, as reflected in the popular press, was precipitated. Theodore Roosevelt called for an immediate solution. Attempts were made at reform through changes in the rules and in the governing institutions. But, as is often the case, true reform comes slowly and during the next few years old strategies were re-employed. A second crisis came in 1909 when the 30 deaths and 216 injuries were well publicized. Serious threats to the continuance of the game also came from a rival sport, rugby. Reforms were reinstituted, debate raged, but again the old pattern of brutal play reoccurred. In 1913 a small team from Notre Dame dramatically changed the game however, with their innovative use of the forward pass. Knute Rockne was the receiver of that first spectacular touchdown pass in the history making game against the West Point Army team. Their 35-13 win saw 13 out of 17 passes completed and the 5 touchdowns all came on completed passes. This new style of play showed that the forward pass was the best ground-gaining play ever developed. It served to open up the game and make it a much more exciting spectator sport. For twenty years the game of football had been in trouble; the sport was almost eliminated.^ While it would be foolish to suggest that the Notre Dame team saved football from extinction, because men like John Hiesman had always been fighting for open play and the forward pass, "They did however help usher in a new era in the sport - the age of the huge stadium". (Moore, 1967) How does this relate to new coal mine development? I believe there are several parallels. A relatively recent crisis in coal mining gained momentum in B.C. in the 1970's when an increase in the exploration activity for coal caused the concerns that were expressed by government resource managers (Dick 1979) and by conservationists (Warden, 1976). The danger was perceived not to be deaths in the mines as was the traditional risk associated with coal extraction but was the large scale land disturbance and associated effects on regional fish and wildlife values. Later the concerns of community well being were added (Halvorson, 1980). This first wave of controversy over exploration and new mine development was followed as it was in football by changes in the rules, new institutions and new regulations. In 1976 the Guidelines for Coal Development were initiated, to be administered by the ELUC Secretariat.  This group was disbanded in September 1980. In 1979 the Coal Mines Regulation Act was revised, to be replaced most recently by the Mines Act (1982).  Following these and numerous other 108 Proceedings of the 7th Annual British Columbia Mine Reclamation Symposium in Victoria, BC, 1983. The Technical and Research Committee on Reclamation changes, prospective mines have to undergo extensive project appraisals prior to obtaining permission to construct the mine and begin production.2 The project appraisal  procedures were designed by their architects to be an all  encompassing assessment which would lead to a political decision-in-principle following the completion of a Stage II assessment (O'Riordan, 1978;   Coal Task Force, 1976). The application of the CDG expanded and changed over time from their initial   inception as participants and administrators became more familiar with the process (O'Riordan, 1981). A second crisis came in 1981 when contracts were signed with the Japanese for N.E. coal   prior to the completion of appraisals for the actual  mines.    In addition, "atypical" mine approvals for other mines brought the credibility of the regulatory process into question.3 A debate accompanied both of the crises as it did in the football controversy.    It was the dimensions of this debate which were the subject of this analysis.4    A questionnaire was administered to 23 individuals each of whom had experience with the CDG.    From the 60 items of the questionnaire a statistical   technique (factor analysis) identified eight aspects of the CDG for which I had a measure of varied respondent attitude.    The relative degree of agreement or disagreement towards the following was measured: a. Information in the prospectus b. Actions from the prospectus c. Planning and preparation of project assessments d. Information existence and availability e. Assessment techniques f. Coordination of the assessments g. Understanding the review procedures h. Coordination of the review process. Another statistical   technique was applied which grouped or clustered the respondent's answers relative to these eight aspects.    This gave me two groups.    One was clearly in agreement with the CDG process and the other group was less satisfied.    A third technique was applied to help to discriminate significant variables from among these eight aspects. From this,  two variables were identified, one as an indicator of the respondent's attitude towards the coordination of the review process 109 Proceedings of the 7th Annual British Columbia Mine Reclamation Symposium in Victoria, BC, 1983. The Technical and Research Committee on Reclamation and another to the planning and preparation of project assessments. A scatter plot (Figure 1)  of these two indicators shows a large variation in attitude.    Four quadrants  appear on this graph.    In quadrant one respondents were satisfied both with  the coordination of the review process and with the planning and preparation of the project assessments.    In quadrants two and three the respondents were either satisfied with one or other of the variables but not both.    In quadrant four the respondent was dissatisfied with both of these aspects.    There was, however,  high  agreement among the respondents on the issues of permitting and licensing,  reclamation, monitoring, information access and regional   planning as  appropriate tools for impact management. What does this mean?    This study suggests that there is a range of opinion as to the degree of agreement participants have with the CDG process.    This may be explained by the differences in the respondents' education,  previous working experience and years of exposure to the CDG program.    These hypotheses were not investigated as a part of this study.    What may be suggested,  however,  is that this range of opinion gives  rise to dissent and a recurring dilemma. Differing individuals or agencies who advance these conflicting perceptions will   often be seen to have retreated into stereotyped positions.    The result of this is  an unnecessary limiting of the possibilities for the flexible appraisal   of particular circumstances. Because the procedures for management,  and the impacts caused by mining are still   being understood, changes in the process are inevitable. Implementation of management plan,  for example,  the Ministry of Environment's strategic plan for managing fish and wildlife values in the S.E. Kootenays means that,  for all   participants,  the goalposts will continue to move.    Introducing innovations such as the reclamation research described today,  has the same effect.    The scale of change is also noteworthy.    In the past, changes have been small  and relatively infrequent.    Individuals have had time to accept 110 Proceedings of the 7th Annual British Columbia Mine Reclamation Symposium in Victoria, BC, 1983. The Technical and Research Committee on Reclamation Figure 1 111  Proceedings of the 7th Annual British Columbia Mine Reclamation Symposium in Victoria, BC, 1983. The Technical and Research Committee on Reclamation change and to readjust. This is no longer the case. The CDG take at least two years to complete, as evidenced by the Greenhills case. Meanwhile, other changes are occurring in the wider economic and political sphere which makes planning without uncertainty impossible. Our ability to predict accurately is severely limited. The acceptance that change is ongoing and inevitably limits the degree of freedom one has in which to operate because each participant has to deal with continual uncertainty. The fact that individuals have concerns with regard to these escalating changes needs to be recognized. The concept of "concerns" used here refers to the attitudes, feelings, perceptions, and motivations of people as they first become aware of a change. The literature suggests^ that there may be several stages or levels of concern an individual may have. The first of these being self concerns, where the individual questions his own adequacy in being able to deal with the change. As these are resolved, task concerns surface which focus on the how-to-deal-with-it aspects of the change. Eventually the questions of concern shift to the impact of the change. The idea of a responsible management attitude towards the environment, the workforce and the community be it regional or provincial in context are now well expressed in the CDG process. Dealing with these ideas has required a change in attitude for many participants. This has resulted in differences from the old way of doing business. A "Walter Camp position" of retaining the old rules and style of play has been unsuccessful. Nevertheless, there are numerous calls for deregulation of the coal mining industry. This is in itself not necessarily a backward step. One suggested solution, "fast-tracking" the CDG to reduce procedural time, may allow companies to take advantage of a very narrow market window. This marketing approach will likely characterize sales within the coal industry for the next few years. But fast-tracking or deregulation is workable only if the concerns of all affected parties are addressed. The "forward pass" for the coal mining game may be characterized as an ongoing education, communication and acceptance process. One rule of thumb for the use of the forward pass is to employ it early in the game to offset the opposition. Creativity in handling this new forward pass, the education/communication process, is now called for. Most planners, be they employed in industry or government, intuitively include educational steps in their implementation plans to lead participants through these stages of concern. This conference is one such example. Another are the CDG themselves. As they are now written they include many philosophical statements of social responsibility in addition to the specifics of the process. However, the CDG focus on the aggregate participant and not on the individual. Thus, the guidelines fail to take into account the wide range of individual attitudes and concerns I have observed. 112  Proceedings of the 7th Annual British Columbia Mine Reclamation Symposium in Victoria, BC, 1983. The Technical and Research Committee on Reclamation A problem has arisen as the CDG proceeded past the initial design and information phase and moved into implementation. A participant profile was prepared from the statements made by the interview respondents. I found certain participants who had entered the process recently, were still at the early stages of self concern. Some had up to now little involvement with the CDG. Their concern was to gain an awareness of the process. Some participants had a general awareness of the process and were interested in learning more detail about the specifics of particular cases. Here there was interest in substantive aspects such as the characteristics of the CDG and their requirements for use. This concern was mainly informational. Some respondents had personal concerns. They were uncertain about the demands of the CDG. There was a great deal of ambiguity and a feeling of not being fully in control of the situation. Often these respondents indicated an unwillingness to participate in the process. There was also an underlying concern that their comments would be seen as negative or career damaging. Other respondents focused the majority of their comments on the tasks required by the CDG. Managing their involvement with the guidelines was their primary concern. Issues related to efficiency, organization, management, scheduling and time demands seemed utmost in their minds. Many respondents had impact concerns. Some focused on the impact of the CDG on their immediate sphere of influence. Concerns centered around performance, competency and outcomes or the consequences of the CDG implementation. Some respondents focused on collaboration concerns. Their attention was on the need for coordination and cooperation with others regarding the application of the CDG. Some respondents in the interviews focused on the broader benefits of the CDG. For example, its use as a model for other review processes was pointed out. Finally some suggested the possibility of major changes in the CDG or replacement with a more powerful alternative. They held definite ideas about options to the existing form of the CDG. Their concern was the need for refocusing the process. With this wide a profile of participant perception, the problem facing those who will revise the CDG is one of synchronizing and addressing participant concerns. The CDG are slated for revision. A complete program evaluation would help in assessing more thoroughly the problems. If it is accepted that an ongoing education process would be the innovative forward pass that could improve your involvement with coal mining and the CDG, the following ground rules might prove helpful. 113 Proceedings of the 7th Annual British Columbia Mine Reclamation Symposium in Victoria, BC, 1983. The Technical and Research Committee on Reclamation 1. Attention must be paid to the individual participant concerns as well as to the mechanics of the project appraisal. 2. Acceptance must be made that individuals will have personal or self concerns. 3. Understanding must be gained that individuals do not change overnight even though the conditions for the game seem to be. 4. Acknowledgement must be made that the participant concerns will not be the same as those of the CDG administrators. 5. Awareness must be developed that within the group there will be a variety of concerns. The method used in this study to identify the concerns was first and foremost to talk about them. Informal dialogue may be the key to determining another individuals' stage of concern. The preparation of a participant profile provides an effective next step because it aids communication and understanding and it helps identify needed action. Formal and informal interventions are possible for any participant who has concerns with any particular CDG procedure. The following set of plays or range of actions may be suitable educating or communicating strategies when addressing the different stages of concern. SELF CONCERNS 1. To improve awareness, speakers may be invited to give presentations. 2. Longer workshops can meet those with informational concerns. 3. Meeting personal concerns takes time and should not be rushed or ignored. Failure to allow time for individuals to talk out their feelings about the change could result in indirect sabotage later on. TASK CONCERNS 4. Management concerns are best handled by expert advisors or consultants. Alternatives for managing the logistics of the problem could then be provided. IMPACT CONCERNS 5. Concerns regarding the consequences are best addressed by asking for feedback and then responding to it. 114 Proceedings of the 7th Annual British Columbia Mine Reclamation Symposium in Victoria, BC, 1983. The Technical and Research Committee on Reclamation 6. To deal  with the concerns regarding collaboration, time is required for interfacing with organizations and providing meeting time for group exchanges. 7. Major changes to the CDG may be necessary to deal  with the refocusing concerns.    Care must be taken that to accomplish this, resources are not spread too thinly. Neither is it implied that by using the new "forward pass"   of a planned education and communication process, coal mining will   never again have to deal with controversy.    After all, the NFL faced a crisis in 1982 with the players'  strike.    The future of football may be again threatened,  this time not by rugby, but by video game surrogates.    A forward pass must anticipate and utilize the attitudes and responses of its receivers.    Adaptive fine-tuning of the education and communication process by using information and flexible channels will provide for learning and will  thereby,  if not eliminate,  at least help to mitigate problems. ACKNOWLEDGEMENTS This paper draws on a much larger study, An Evaluation of the Guidelines for Coal Development, British CoIumbia (1983).    A considerable amount of material  has been gathered for that study which is not cited specifically in this paper.    Numerous interview sources, both those obtained formally and through informal  conversations,  have allowed a "piecing together" of information.    The author is grateful for the generous comments received from all who contributed their time and knowledge. 115 Proceedings of the 7th Annual British Columbia Mine Reclamation Symposium in Victoria, BC, 1983. The Technical and Research Committee on Reclamation NOTES 1. Other historians suggest that the game of football was probably never in any real danger of being abolished. The analysis by Moore (1967) does give an indication that it is the perceptions of risk that build a crisis. Actions may be  taken  to  reduce  the  risk  by changing  rules, institutions, training or equipment.  The initiation of these changes may be mainly a political responsibility. But a true reduction of the risk and elimination of the crisis does not occur until the actual participants in the game adaptively change their attitudes and actions.  For further analysis regarding crises see Smart, C.F. and W.T. Stanbury (eds.), 1978.   Studies on Crises Management. Institute for Research on Public Policy, Butterworth & Co. (Canada) Ltd., Toronto. 195 p. 2. An account of institutional changes up to 1976 may be found in: Crook, R.L. and C.K. Stackelrodt-Crook, 1976. "Towards a Land Use Management Philosophy in British Columbia", a paper presented to the conference on Monitoring for Environmental Protection, Association of Professional Engineers of British Columbia and Environment Protection Service - Environment Canada, U.B.C., February 12th-13th. A more complete analysis of the evolution of B.C. land use policies and practices is presented in: Crook, C.K., Stackelrodt, 1975. Environment and Land Use Policies and Practices of the Province of British Columbia. British Columbia Institute for Economic Policy Analysis, Victoria, B.C. A recent compendium of institutional arrangements for resource management may be found in the draft appendix: 116 Proceedings of the 7th Annual British Columbia Mine Reclamation Symposium in Victoria, BC, 1983. The Technical and Research Committee on Reclamation Crook, R.L., April 1982. Northeast Coal Study. Resource Planning Framework; Appendix, Institutional Framework for Resource Management, (first draft), Inspection and Engineering Branch: Ministry of Energy, Mines and Petroleum Resources, Victoria, B.C. 3. In fact, it was more than the regulatory CDG that were questioned. It was the entire political decision-making process and government planning procedures which were criticized. The following critiques illustrate the range of perceptions surrounding this crisis: Dick, J.H. and N. Ringstad, 1981. "The Guidelines for Coal Development - A Review", a joint Planning Branch -Fish and Wildlife Branch document, submitted to Dr. Lance Regan, Section Manager, Guidelines Assessment Branch, Ministry of Environment, Victoria, B.C. - identifies the need for MOE to better organize its role  relative to  the  CDG  (suggests  need  for identification of Ministry goals and objectives). - identifies the need for the CDG process to clarify who makes the decisions (suggests senior executive) and when are the decisions made (suggests at the prospectus stage). Hawes, R. and J.W. Gadsby, 1982. "Managing Environmental Requirements for New Developments in British Columbia". A paper presented to the Sixth Annual British Columbia Mine Reclamation Symposium, Vernon, March 10-12. -  identifies the political component as an unpredictable element in the CDG process (suggests companies adapt a specific environmental management strategy). Keevil, Jr. N. 1983, "Project Assessment: Western Canada Coal Development" introductory remarks, Banff School of Management, January 23. 117 Proceedings of the 7th Annual British Columbia Mine Reclamation Symposium in Victoria, BC, 1983. The Technical and Research Committee on Reclamation - identifies the problem as new and everchanging regulations and individuals in review agencies who don't understand or agree with the regulations and have little experience with mining. - suggests, given the unpredictable nature of coal markets, that finding new coal mine markets and financing should proceed regulatory approvals. Livernois, J.F., 1980, "Summary Evaluation of Northest Coal Development in B.C.", Resources Paper #53, Department of Economics, U.B.C. -  identifies the problem as excessive public subsidization which will be required for N.E. coal development. - suggests that a possible rise in future coal prices and  employment  creation  are  not  acceptable rationalizations of this public investment. New Democratic Party Caucus of B.C., 1981, "Coal Deal Signing Premature Say Government's Own Advisors", news release, February 9. - identifies the confidential cabinet committee decisions re coal development as the problem. - suggests public legislative examination of coal related decisions is necessary. 4. This paper describes the findings and some recommendations for utilization from only one portion (*) of the larger thesis, An Evaluation of the Guidelines for Coal Development, British Columbia. The model for this evaluation is modified from Day, J.C. et al. 1977, "A Strategy for Hindsight Evaluation of Environmental Impacts", proceedings from a conference on Environmental Impact Assessment, University of Waterloo, Ontario. The thesis includes an examination of: 118 Proceedings of the 7th Annual British Columbia Mine Reclamation Symposium in Victoria, BC, 1983. The Technical and Research Committee on Reclamation o  the  goals,  objectives  and  policies  for  coal development in B.C. o  the historical context in which the CDG evolved, o  the  institutional framework for coal development in B.C. o  the actions of the CDG in three specific cases; Line        Creek, Greenhills and Sukunka. (*)     o  the impacts of the CDG as viewed by the participants    of the process. This evidence is collected to determine which aspects of the CDG are effective and should be retained, and which are deficient and require improvement. 5.  A summary which identifies the need to understand the factors that influence human motivation before changes are made to environmental regulatory agencies, is prepared by Starrs, C.J., 1982, "Environmental Ethics ... and Beyond: The Human Side of the Man-Environment Relationship", in a series of essays prepared for discussion, Environment Canada, (draft), Ottawa. (With particular reference to Chapter II "Human Development: A Psychological Perspective.") Practical  suggestions for developing and implementing communication strategies are described in: Ackley, P. 1981, "Stages of Concern", mimeograph. Vertinsky, I. and P. Vertinsky, 1980. "Communicating Environmental Health Risk Assessment and Other Risk Information: Analysis of Strategies". A paper funded by Environmental Health Directorate, Health Protection Branch, Health and Welfare Canada. Strategies are also described for the public involvement question in: Sadler, B. (ed.), 1979, Public Participation in Environmental Decision Making; Strategies For Change, proceedings of a National Workshop April 17-20, Banff, Alberta., organized by the Environment Council of Alberta and the Banff Center for Continuing Education, 177 p. 119 Proceedings of the 7th Annual British Columbia Mine Reclamation Symposium in Victoria, BC, 1983. The Technical and Research Committee on Reclamation 120 REFERENCES Dick, J.H., 1979. "The Process of Assessing the Environmental Impacts of Coal Development in B.C." from notes, personnal communication. Coal Task Force, 1976. Coal in British Columbia. A Technical Appraisal. Report of the Technical Committee, Victoria, B.C. Halvorson, H.N., 1980. "New Coal Production From Southeastern B.C. Compared With Proposed Northeastern B.C. Development". A study for the council of Mayors of Southeastern British Columbia. Moore, J.H., 1967, "Football's Ugly Decades, 1893-1913." Smithsonian Journal of History. Vol. 2, pp. 49-68. O'Riordan, J., 1979. "Coal Development Guidelines in British Columbia" in Mohan K. Wali (ed.), Ecology and Coal Resource Development. Vol. 1, Pergamon Press,pjT207-213. O'Riordan, J. 1981. "The British Columbia Experience", in T. O'Riordan and W.R.D. Sewell (eds.), Project Appraisal and Policy Review. John Wiley and Sons Ltd., Toronto, pp. 95- 123.      


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