Canadian Premium Sand (CPS), an Alberta-based company whose board of directors are all former oil and gas executives, received an Environment Act Licence from the government of Manitoba in May 2019. The license will enable CPS to proceed to the construction phase of its proposed silica sand mine, as well as the construction of a wet and dry plant to process 1.3 million tonnes of silica sand a year for at least 30 years, for use as proppant in the fracking industry.

The processed silica sand from the mine, located adjacent to Hollow Water First Nation, which is about a two-and-a-half-hour drive north of Winnipeg along the eastern shores of Lake Winnipeg, would then be transported via trucks at a rate of 120 loads per day, every day of the year, to an offloading facility in the provincial capital.

However, in 2021, CPS made an announcement that they had completely changed their development intention and have now identified some 7.2 million tonnes of high-grade silica sand that they wish to mine at a rate of 300,000 tonnes a year, over 25 years, to use as raw material to make patterned solar glass. The product will be produced at a $443 million dollar float glass plant CPS proposes to construct in Selkirk, Manitoba.

CPS still maintains that 25 million tonnes of silica sand, for use as proppant, is still of material interest to the company in their October 2021 National Instruments 43-101 Technical Report, a legally required document for all mining companies who trade on the Toronto Stock Exchange, which provides transparent information on all aspect of a company business to potential investors.

There is nothing stopping CPS from making an alteration request to their Environment Act Licence to the province of Manitoba at some future date. This would allow the company to increase its yearly production rate, and to sell its silica sand mined as proppant for use in the fracking industry.

So far, only preliminary site clearing has occurred at the proposed silica sand mine site, and no construction has yet begun on CPS original development intention since receiving its Environment Act Licence more than three years ago. This is due largely to the fact that CPS has been unable to find investors or obtain the necessary up-front financial capital to proceed to the construction phase of its proposed resource development project.

In the Environment Act Licence that CPS received in 2019, there contains a review and revocation provision with three clauses, which have now been triggered. Clause B states: “If the Licencee has not commenced construction of the Development within three years of the date of this Licence, the Licence is revoked.”

Three years have now passed, but CPS is under the impression that all they need to do is apply to the government of Manitoba for an alteration request to their existing Environment Act Licence for the proposed new development intentions—even though their Environment Act Licence is now revoked.

Under the Manitoba Environment Act, CPS will need to submit a completely new Environment Act Proposal, for both its newly revamped mining related activities and for its proposed float glass plant, which will need to be reviewed and approved by the province.

Meanwhile, the elected leadership of Hollow Water First Nation completely undermined the community’s Treaty 5 and Section 35 rights by signing a memorandum of understanding with CPS and receiving a $250,000 payment to support the development project in November 2018. This was done without the free, prior and informed consent of its community members, allowing CPS to proceed with preliminary site clearing of the silica sand mine site, situated on a community designated trapline, thus directly undermining the community’s constitutionally protected rights to hunt, trap, gather medicines and pick berries.

This inaction by the elected leadership of Hollow Water First Nation to defend the community’s Treaty and Section 35 rights, led some in the community to set up Camp Morningstar in February 2019. The camp, which is located on an access road leading to the proposed silica sand mine site, was erected to bring much-needed attention and education to this issue to other community members. The camp has now been operating for almost three-and-a-half years.

The proposed CPS silica sand mine will most likely create acid mine drainage issues from the open pit mining process. What’s more, possible health issues could arise from fine silica sand dust, which, once mined, can cause silicosis (a long-term lung disease) for those working and living near the site.

The adverse environmental impacts of acid mine drainage can been seen first-hand at an abandon silica sand mine that operated on Black Island from the 1920s to the 1990s, just a short boat ride from where CPS is proposing to mine silica sand on the mainland.

One elder from Hollow Water First Nation noted the spiritual importance of silica sand to his community. As other elders told him, “this is the sand in the spring time when the thunderbeings come and they activate the healing energy of the sand; this sand is like a filter for all the water we have here in this region, from the rain, the rivers, the lakes and the underground streams.”

CPS must first process the mined silica sand to get the iron content low enough to be able to make patterned solar glass.

The beneficiation process used to achieve this low iron content may employ the use of a toxic acid washing process.

This wash plant will be located at the mine site, creating yet another toxic waste stream that the community will have to contend with. Once the silica sand has been processed, it will then be transported via trucks to the proposed float glass plant in Selkirk, at rate of 80 loads a day for ten months out of the year.

But there already exists stockpiles of high-grade silica, also known as sandstone, which can be transported via rail, by a number of rail carrier companies (including Canadian ones) directly to their proposed float glass plant in Selkirk.

Wisconsin produces 21 million tons of high-grade silica every year, which can be transported in a cost-effective manner, via rail, directly to the proposed float glass plant in Selkirk (silica mining companies operating in Wisconsin are highly integrated operations). Any impurities, such as iron, found in this silica in Wisconsin—and they are minimal—can be washed out on-site at the proposed float glass plant in Selkirk.

This would save CPS millions in start costs to get their silica sand mine operational and also save them money on the annual operating costs associated with their silica sand mine.

It would also eliminate both the health issues and the adverse environmental impact associated with the open pit mining process for those living near the proposed silica sand mine.

Importing silica from Wisconsin would also avoid the traffic-related issues associated with hauling upwards of 80 truck loads of processed silica sand a day from the silica sand mine site to the proposed float glass plant in Selkirk. These issues including the likelihood of increased traffic fatalities for those who use Highways 304 and 59 for their daily commute, or for those who make frequent commutes during the summer months to their cottages in the East Beach area and up to Manigotagan, or for the half-a-million visitors who come to enjoy Grand Beach provincial park every year.

Additionally, there would be a cost saving to taxpayers associated with having to maintain the road infrastructure with this increased heavy truck traffic along these two stretches of highways.

Finally, it would eliminate a new source of greenhouse gases, as transporting all this processed silica sand via trucks would create some additional 4,680,000 kilograms of emissions every year and 117,000,000 kilograms of GHGs over the life of the project, which CPS states would be 25 years.

The mining of silica sand on a community-designated trapline adjacent to the Hollow Water First Nation’s reserve boundary is poised to be a disaster for the environment. But this can all be avoided if CPS gets the silica it needs to feed its proposed float glass plant from Wisconsin, instead of despoiling a sensitive ecosystem for profit and convenience.

Don Sullivan is spokesperson for What The Frack Manitoba, the former Director of the Boreal Forest Network and served as special adviser to the government of Manitoba Pimachiowin Aki UNESCO World Heritage site portfolio. He is a research associate with Manitoba’s Canadian Centre for Policy Alternatives and a Queen’s Golden Jubilee medal recipient.