May 15, 2019 The Honorable Michelle Mungall Minister of Energy, Mines and Petroleum Resources PO Box 9060 Stn Prov Govt Victoria, BC V8W 9E2 Re: Imperial Metals Corporation, Notice of Work – Upper Skagit River Exploration Multi-year, Area Based Permit Application, Mine No. 0700195 Dear Minister Mungall: I am writing to provide my formal comments regarding our concern about the mining resource extraction activities proposed for the Silverdaisy area in the Upper Skagit Watershed. We strongly believe this area was intended to be protected by the 1984 US-Canada High Ross Treaty and the agreement between the City of Seattle and British Columbia (BC). In the past month, we have learned from the Skagit Environmental Endowment Commission (SEEC) that further timber sales in the Silverdaisy area, known as “the donut hole,” have been put on hold and that the roads that were constructed to support this logging are already being deactivated. I want to thank Minister Donaldson and the BC government for their actions to protect the fragile ecosystem and for recognizing that roadbuilding and logging in this area undermines protection of the area as intended by the Treaty. However, our concern has now shifted to the announcement in late March that Imperial Metals has applied for a permit to undertake mineral exploration in the Silverdaisy area, taking advantage of the roads that were built to facilitate the timber harvest. With the official public comment period currently open, I know you have already heard from concerned parties, including several Native American tribes and First Nations, about their opposition to such activities in the area. I would like to add the City’s voice to theirs and the many others you will hear from regarding this troubling proposal. Recent history only shows the potential danger too well. As you know, the company that has applied for this permit, Imperial Metals, was responsible for the 2014 disaster in northern BC involving the breach of a tailings pond at the Mount Polley mine and the pollution of Lake Quesnel. The breach released more than 30 million cubic yards of toxic water and sediment into a salmon-bearing watershed known for its large sockeye salmon runs. The event has raised major concern over engineering standards and regulation of the mining industry in BC. The area has still not been restored by Imperial Metals. Our review of the Imperial Metals exploration permit has raised significant concerns, particularly given the City’s own expertise in meeting rigorous water quality standards and implementing environmental remediation. The City of Seattle firmly maintains that the activities proposed, including construction of access roads and trails, surface exploration drilling with associated water supply and catchment sumps, Office of the Mayor 600 Fourth Avenue, P.O. Box 94749, Seattle, WA 98124 206-684-4000 seattle.gov/mayor and mechanical trenching, settling ponds and test pits for a period of up to five years, are not consistent with the provisions of the High Ross Treaty. We are obligated and will take all possible steps to protect the treaty rights and the significant federal, state, and local water quality and wildlife habitat investments that have been made on the United States side of this transboundary watershed. We trust that the BC government will do the same. The High Ross Treaty has served as a model for transboundary collaboration and it includes an obligation and also a roadmap for permanent protection of the Upper Skagit Watershed. I have asked Premier Horgan to join me in committing to work with the SEEC on securing acquisition of the mineral rights and transferring the “donut hole” into the BC Parks system. It is incumbent on us to carry out the work of those who dedicated their time and efforts to forge this historic agreement some 35 years ago and work to ensure the outcome they identified in the Treaty. We understand that you are overseeing the permit process consistent with the BC Mines Act, which also provides that the minister has and may exercise all the powers that the chief inspector may exercise in respect to issuing permits, if the minister considers it be in the public interest. We urge you to use this power vested in you by the Mines Act and deny this permit in the undisputed public interest in protecting this area at the headwaters of the Skagit. Lynn Best, Seattle City Light’s Environmental Affairs Officer, continues to engage with Pierrette Maranda from Premier Horgan’s office and with Chris Trumpy and David Caughill of your Ministry. I thank you for this ongoing cooperation and hope together we act with urgency, as time is of the essence for BC to affirm our shared commitment to achieving the permanent protection of the Upper Skagit as envisioned in the High Ross Treaty. Sincerely, Jenny A. Durkan Mayor of Seattle Cc: Honorable Jay Inslee, Governor, State of Washington Honorable John Horgan, Premier, British Columbia Honorable Doug Donaldson, Minster of Forest, Lands, and Natural Resources, British Columbia Chief Inspector of Mines, Ministry of Energy, Mines & Petroleum, British Columbia Honorable George Heyman, Minister of Environment and Climate Change Strategy, British Columbia Leo Bodensteiner, SEEC US Co-Chair Thomas Curley, SEEC Canada Co-Chair Debra Smith, General Manager/CEO, Seattle City Light