<http://www.w3.org/2009/08/skos-reference/skos.html#note>
"MINE RECLAMATION AND THE BRITISH COLUMBIA ENVIRONMENTAL ASSESSMENT PROCESS  Graeme McLaren, M.Sc. BC Environmental Assessment Office 1-836 Yates Street PO Box 9426 Stn Prov Govt Victoria, BC V8W 9V1 ABSTRACT Major mining projects in British Columbia are subject to review through the Environmental Assessment (EA) process as a means of ensuring the potential for adverse environmental, social, economic, health and heritage effects or for adverse effects on asserted Aboriginal interests or rights are addressed prior to an EA Certificate decision. Two stages in the EA process provide for a structured review that confirms appropriate information, including conceptual reclamation plans, is in an application for an EA Certificate. There are currently 20 mining projects in the EA process; 18 projects reviews have been completed through a typical EA review and certified since 1995. An informal review of recently certified mine projects found a number of common and pressing reclamation issues facing all mining proposals, whether they be metal, coal, aggregate or industrial mineral mining projects. However the importance of any given issue varies according to the type of project or the location and consequently, approaches to addressing the issues adapt to these variations. The EA process adds value to the planning for a project by ensuring a wide range of views, interests and rights are fully considered in establishing reclamation objectives and in the reclamation plans designed to achieve those objectives. INTRODUCTION The British Columbia Environmental Assessment Act (S.B.C. 2002, c. 43) (BCEAA) requires that certain major project proposals obtain an EA certificate before they can proceed. The types of projects that may be subject to the Act include industrial, mining, energy, water management, waste disposal, food processing, transportation and tourist destination resort projects. The current legislation came into effect on December 30, 2002, replacing the previous Environmental Assessment Act (R.S.B.C. 1996, c. 119), which had been in effect since June 30, 1995. The BCEAA ensures that proposed projects subject to the legislation undergo a comprehensive, integrated, coordinated and timely assessment, within the context of prevailing public policy. The legislation and accompanying regulations establish the framework for delivering environmental assessments. However, the scope, procedures and methods of each assessment are flexible and tailored specifically to the circumstances of the proposed project. This flexibility is important in addressing some of the unique issues presented during the reviews of major mining projects, including the long-term maintenance of residual effects and the reclamation of a mine site. In general, an environmental assessment includes four main elements: 1. opportunities for all interested parties, including First Nations and neighbouring jurisdictions, to identify issues and provide input;  \u000C2. technical studies of the relevant environmental, social, economic, heritage and health effects of the proposed project; 3. identification of ways to prevent or minimize undesirable effects and enhance desirable effects; and 4. consideration of the input of all interested parties in compiling the assessment findings and making recommendations about project acceptability. An EA certificate, if issued by ministers at the conclusion of an EA, represents government's approval in principle and allows a proponent to seek any other statutory authorizations needed to construct and operate the project. Mine projects may also be subject to the Canadian Environmental Assessment Act. Where federal and provincial environmental assessment legislation applies to the same project, Canada and British Columbia have entered into an Agreement on Environmental Assessment Cooperation whereby projects will undergo a single, cooperative assessment, meeting the legal requirements of both governments while maintaining their respective existing roles and responsibilities. This paper will not address federal process requirements in any detail and the reader is referred to the Canadian Environmental Assessment Agency for more information on the federal review process. Further information on the Cooperation Agreement can be found at: http://www.eao.gov.bc.ca/pub/can-bc_agreement/ . This paper provides a brief overview of the BC EA process, with a focus on key steps and requirements that have direct bearing on reclamation issues. It also contains a summary of mining projects that have been reviewed under the BCEAA since 1995 and from those projects selected examples are used to illustrate how key reclamation issues have been considered. THE BC ENVIRONMENTAL ASSESSMENT (EA) PROCESS There are two stages in BC\u2019s EA process: Pre-Application and Application Review (Figure 1). Pre-Application The pre-application stage begins when a mine proponent files an initial project description with the Environmental Assessment Office (EAO). The Reviewable Projects Regulation sets thresholds for reviewable projects based on rate of production capacity; modifications to existing projects may also be considered reviewable projects based largely on incremental land disturbance resulting from the modification. There are separate thresholds for categories of mines (metal, coal, etc.) but in general, all major mining projects are subject to an EA review. Once a project is deemed reviewable, subsequent key steps in the pre-application stage include: \u0083 determining the review path, which is typically led by BC EAO staff; \u0083 identifying issues that need to be addressed; and \u0083 developing Terms of Reference for the Application. In establishing the review path, the EAO issues a procedural order to the proponent that, among other directions, specifies the scope of the project subject to review and the scope of the assessment. The scope  \u000Cof project, which includes both on-site and off-site project components and activities, is important in that it leads to clarifying the mine components and activities that must be addressed in reclamation plans. The scope of the assessment normally includes consideration of: \u0083 potential adverse environmental, social, economic, health and heritage effects and practical means to prevent or reduce to an acceptable lever any such potential adverse effects; and, \u0083 potential adverse effects on First Nations interests or rights and to the extent appropriate, ways to avoid, mitigate or otherwise accommodate such potential adverse effects. It is clear that reclamation activities play a major role in addressing many of the effects that fall within the above scope of the project assessment and as a result, the conceptual-level reclamation and closure plans in a project application take on considerable importance during the EA review process. Figure 1: Two stages in the BC Environmental Assessment Process  BC Environmental Assessment Process Pre-Application Stage N O  T I M E  Project Confirmed as Reviewable Under BCEAA EAO issues Procedural Requirements* Information Requirements developed for Certificate Application  Application Review Application Submitted and Screened Stage for Consistency with Requirements* Application Receives Formal Public, Agency &amp; First Nations Review &amp; Comment*  EAO Prepares Draft Assessment Report for Technical Review*  I  Information Requirements (TOR) Receive Formal First Nation, Public &amp; Agency Comment  N  Information Requirement Approved*  Submission of Assessment Report &amp; Recommendations to Ministers  Application Document Prepared  Ministers Decision on EA Certificate  L  E  30 DAYS  180 DAYS  45 DAYS  * Process harmonized with federal EA where applicable  The Terms of Reference for a project identify the issues to be addressed and the information to be provided by the proponent in their Application for an EA Certificate. The Terms of Reference are drafted by the proponent and are reviewed by an EA technical Working Group and the public; the EAO is responsible for approving and issuing the final Terms of Reference. Once issued, the proponent has clear guidance on completing their Application for an EA Certificate. All phases of the proposed project are addressed in the Terms of Reference, including planning, construction, operation and decommissioning. As part of decommissioning, conceptual plans for closure, reclamation, removal of structures and ancillary equipment and site remediation are addressed. The Terms of Reference also identify a requirement for a  \u000Cnumber of environmental management plans, which can be expected to address long term management concerns (such as water quality, waste rock and tailings) as well as shorter-term plans for progressive reclamation during operations. A specific conceptual-level closure and reclamation plan is also addressed in the Terms of Reference. Application Review The government decision to accept an Application is based on whether or not the Application provides the information required by the approved Terms of Reference; this initial evaluation (or screening) must be completed within 30 days of receipt of the Application. If information is missing, the proponent is required to correct this deficiency. Once the Application is accepted the EAO has up to 180 days to review it and make recommendations to Ministers. The EAO strives to complete the review within this 180-day timeline; however there are specific means by which that timeline can be extended if required. A government decision to issue an EA Certificate is based on how effectively the Application addresses the issues identified in the Terms of Reference and the ability of proposed measures to mitigate adverse project effects, which is determined during the 180-day formal Application review stage. Key steps in assessing the potential effects of a mine project are summarized in Table 1. Table 1: Key steps in assessing the potential effects of a project. Step Description 1. Describe the Project - sufficiently detailed description of components and activities to identify potential issues and information requirements; Include a preliminary mine plan as per the Health, Safety and Reclamation Code for Mines in British Columbia. 2. Scope the Issues - through discussions with the EA Working Group and public review of the draft Terms of Reference 3. Confirm the Issues - describe those components of the project setting (environmental, socioeconomic, heritage, and health) that will or could be affected by the project 4. Select the \u201CValued - VECs are parameters of the project that are considered suitable indicators of Environmental the significance of a project\u2019s potential effects and as such, they provide focus Components\u201D (VECs) for the impact assessment; VEC selection is guided by professional judgement and by expressed public, First Nation and government concerns 5. Describe the Project - identify and describe all components of a project setting that could be Setting (through baseline affected by the development; sufficient detail is required to enable the impact studies, etc) assessment, therefore in many instances multiple years of baseline data is required. 6. Identify Potential - describe the nature and extent of the potential impacts of interactions Effects between the project and the existing project setting. 7. Develop Management - describe the proposed measures (avoidance, mitigation, compensation) to Proposals manage the impacts identified in step 6. 8. Define Residual - develop rating criteria for potential residual effects of the project on each Effects Rating Criteria VEC (such as for the magnitude, geographic extent, duration, frequency and reversibility of predicted residual effects). 9. Estimate Potential - assess the significance of residual effects and the level of confidence in the Residual Effects with impact predictions. Mitigation  \u000CReclamation considerations become particularly important in steps 7-9 during the assessment of operational activities. During these steps, planning for progressive reclamation of disturbances during operations, where possible, are normally employed as a mitigative measure to reduce the impacts of the project. The decommissioning phase of the mine project must be described in the project Application and the effects of decommissioning activities must be assessed. A conceptual-level decommissioning and reclamation plan is also required. This plan should set out; \u0083 an overview of the proposed reclamation plan, by phase, timing and duration; \u0083 plans for progressive reclamation, as mining advances; \u0083 plans for permanent decommissioning of the mine (removal of equipment and structures); \u0083 details of the long-term management of any dams and other structures; \u0083 the long-term objectives for future use of the property following decommissioning (e.g. end land use objectives); and \u0083 any other post closure plans and obligations. The reclamation plan should be evaluated in terms of its probable effectiveness, assessing risks of failure and the magnitude of any environmental effects associated with a failure of the plan to achieve its objectives. Any potential for failures of long-term dam structures should be assessed, together with the expected implications for public health, the environment and property in the event of a failure, and suggested remediation approaches. The plan should provide an overview of the key site reclamation options which were considered and explain the rationale for selecting some and rejecting others. The plan should also identify responsibilities for implementing site reclamation measures, and the system for accountability, including the respective obligations of the proponent and contractors, both during operations and after mine closure. Finding the right balance between provision of conceptual level information during the EA review and more detailed information during subsequent Mines Act permitting is often a challenge during the EA process as some participants in the review process seek greater detail and/or assurances on reclamation and closure activities. A critical part of the Application is the Table of Commitments and Assurances that summarizes all key actions that the proponent will undertake in carrying out the project. Many of these commitments evolve directly from the avoidance and mitigation measures proposed and are normally modified or expanded on during the Application review to respond to concerns expressed by First Nations, government agencies or the public. Since the commitments become part of the EA Certificate issued under the BCEAA, all commitments relating to reclamation and long term environmental management measures take on great importance in the EA review process. The Application review stage is completed when the EAO submits a Project Assessment Report, which summarizes the issues considered during the review,and associated information to the Ministers of Environment and Energy, Mines and Petroleum Resources for their decision on whether to issue an EA Certificate. The Ministers have up to 45 days to make their decision. As noted earlier, issuance of an EA Certificate for a project is a notification of government\u2019s approval in principle for a mine project. With an EA Certificate in hand, proponents are still required to obtain all other statutory authorizations, such as a  \u000CMines Act permit, before proceeding with the development. It should be noted that there are provisions in the Concurrent Permitting Regulation of the BCEAA to allow a proponent to apply for other authorizations while the EA process is underway and to receive a response to their permit applications within 60 days of the issuance of an EA Certificate. MINING PROJECTS IN THE EA PROCESS (1995-2008) Table 2 lists all mining projects that have been subject to the typical EA review process (described above) from 1995 when the BCEAA was created to the present. There are 20 mining projects currently in the EA process (although not all are under active review at this time). A total of 18 projects have been completed and certified and some of these EA certificates were subsequently amended. Figure 2 illustrates where these projects are located in the province. From 2002 to present, the 8 projects certified (3 metal mines, 2 coal mines, 3 aggregate mines) represent almost $3 billion of capital investment (not adjusted to current dollars) and over 2000 permanent jobs, as described in the project applications. RECLAMATION ISSUES The EA process draws heavily on technical expertise from other government agencies (and their respective legislative mandates) during any project review. The expertise provided by the Ministry of Energy, Mines and Petroleum Resources (MEMPR) and the requirements of the Health, Safety and Reclamation Code for Mines in British Columbia is a prime example of this. In addition, the process Table 2: Mining Projects subject to the typical EA Process, 1995-present Currently in the EA Process (Pre-application and Application Review) * Project Start Date Bear River Gravel Project 2005/03/08 Cariboo Gold Project 2000/04/11 Cogburn Magnesium Project 2005/03/24 Davidson Project 2005/07/18 Gething Coal Project 2006/11/10 Giscome Quarry and Lime Project 2007/04/19 Herman Mine Coal Project 2006/07/06 Hills Bar Aggregate Quarrying Project 2003/07/21 Horizon Mine Coal Project 2005/09/20 Kerr-Sulphurets-Mitchell Project 2008/04/25 Kutcho Copper-Zinc-Silver-Gold Project 2005/07/29 Lodgepole Coal Mine Project 2006/01/09 Morrison Copper/Gold Project 2003/09/30 Mount Klappan Coal Project 2004/10/08 Mt. Milligan Gold/Copper Project (2006) 2006/10/13 Prosperity Gold/Copper Project 1995/06/30  Certified Date  \u000CTable 2 (continued): Mining Projects subject to the typical EA Process, 1995-present Currently in the EA Process (Pre-application and Application Review) * Project Start Date Certified Date Roman Coal Mine Project 2007/09/11 Schaft Creek Copper-Gold-Molybdenum-Silver Project 2006/08/14 Sechelt Carbonate Project 2005/11/23 Sustut Copper Project 2003/03/28 Completed / Certified Bodie Dump 1995/06/30 1996/02/23 Brule Mine Project 2005/01/13 2006/07/04 Cougar Pit Coal 1995/06/30 1997/04/24# Eagle Rock Quarry Project 2002/12/16 2003/09/17 Elkhorn Quarry Extension Project 1995/06/30 1995/09/19 Galore Creek Copper-Gold-Silver Project 2004/02/25 2007/02/16# Huckleberry Copper and Gold Mine 1995/06/30 1995/12/22# Kemess South Project 1995/06/30 1996/04/29 McGillivray Coal 1996/01/04 1996/07/24 Nazko Lava Quarry Extension Project 1995/06/30 1996/02/22 Orca Sand and Gravel Project 2003/09/30 2005/07/14 Red Chris Porphyry Copper-Gold Mine Project 2003/11/26 2005/08/24 Ruby Creek Molybdenum 2005/06/08 2007/09/10 Swamp Point Aggregate Mine Project 2005/04/07 2006/06/21 Tom McKay Lake Waste Rock &amp; Tailings Project 2000/02/18 2000/07/21 Tulsequah Chief Project 2000/09/19 1998/03/19# Willow Creek Project 1995/06/30 1998/03/06 Wolverine Coal Mine 2001/12/31 2005/01/13# * Project may be under active review or may currently be dormant, awaiting additional information or action from the proponent. # Initial EA certificate was subsequently amended. seeks input from First Nations on their views regarding each proposed project and the potential for impacts on Aboriginal rights or interests. First Nation people are often able to contribute valuable aspects of traditional knowledge that benefit planning for the mine development, including the closure and reclamation activities. First Nation input to the post-mining land use objectives, expressed in the conceptual closure and reclamation plan during the EA review, is also particularly important for addressing the potential for impacts to First Nation interests or rights and in finding ways to avoid, minimize or mitigate such impacts. At the EA Application review stage, detailed engineering and plans for most mine components may not be finalized and therefore a conceptual-level reclamation and closure plan is required for an EA review. This also recognizes that a mine life may extend over many decades and the closure and reclamation plan will evolve with the mine plan over that time.  \u000CFigure 2: Locations of Mining Projects subject to a typical EA Process, 1995-2008  Completed / Certified Currently under review  Mine Category  Completed / Certified  Under Review  Coal  6  6  Metal  7  10  Aggregate  4  2  Industrial Mineral  1  2  Mine developments disrupt existing land uses and the local environment and not all disturbances can be returned to their pre-mining state. The overarching reclamation objective of returning lands to a productive state involves, among other things, ensuring there are stable landforms, an appropriate mix of vegetation and stable growth rates and a suitable combination of terrestrial and aquatic wildlife habitat components. Removal of buildings, roadways and other physical components are also normally required to achieve this objective, however there may also be opportunities for keeping certain buildings or infrastructure through ongoing consultation on mine closure plans with other parties who may be willing to take on responsibilities for specific assets. The EA process provides an opportunity for technical experts from government agencies, First Nations and the public to review and comment on proposed end land use objectives and the means to achieve them. Given that most mines in BC are located in remote areas, fish and wildlife habitat dominate the descriptions of pre-mining land uses and therefore closure plan objectives focus on restoring this habitat. Fish and wildlife and their habitat are an integral component of First Nation interests in BC and the EA process affords an opportunity to ensure the objectives of both the mining proponent and any affected First Nations can be aligned. As an example, the Taku River Tlingit First Nation (TRTFN), in their  \u000COctober 2006 preliminary response to the Ruby Creek Molybdenum Project Application, sought additional information on the objectives relating to each component of closure activities, including objectives for temporary closure measures. This was in addition to more specific questions about aspects of the closure plan. Issues raised during an EA review process by the EA technical Working Group or the public are tracked so that the proponent\u2019s response to the issues can be assessed to determine if they are acceptable. In this example, the proponent subsequently submitted an Addendum to their Application on the Closure Plan to respond to TRTFN concerns. Similar examples can be found by reviewing the Working Group issues tracking tables included in Assessment Reports in various project folders on the EAO website. A review of mine project applications listed in Table 2 confirms that the most common and pressing issues that typically arise within reclamation and closure planning relate to: water quality and metal leaching / acid rock drainage; protection of fish and fish habitat; protection of terrestrial ecosystems; restoration of disturbances to vegetation and soils; measures to safeguard wildlife and wildlife habitat; restoration of disturbances related to roads and other infrastructure; maintaining air quality; shaping / contouring manmade structures for physical stability; and, managing visual impacts. Ensuring that there is a commitment to maintain an up to date mine closure plan and an ongoing monitoring and reporting plan is an important consideration that ties all of the above issues together. Although the relative priority or importance of each issue may vary, the types of issues to be addressed are relatively consistent across metal, coal and aggregate mines (with the possible exception of ML/ARD issues in some aggregate mines). Table 3 summarizes a few examples of how the above issues have been addressed in different types of mining projects that have received EA Certificates in recent years; examples are drawn from project reclamation and closure plans presented in proponent\u2019s EA Applications or from the proponent\u2019s Table of Commitments. The examples were selected in part to demonstrate the diversity of both the nature of an issue and approaches to addressing them. The EA review process ensures that appropriate technical expertise, First Nation interests, rights and expertise and public views are all incorporated into establishing reclamation objectives and activities during mining operations and during closure or decommissioning of a mine site. The process adds value in either confirming proposals made in the Application for an EA Certificate or in building on the existing proposals to improve and develop them into an overall mine plan that meets the requirements of the Act. Additional information about the EA process or any of the projects discussed in this paper can be found on the EAO website at: www.eao.gov.bc.ca . ACKNOWLEDGEMENTS This paper has greatly benefited from research, information and review provided by a number of staff at the EAO including Joe Truscott, Rachel Shaw, Tedd Drummond and Anne Currie (currently on assignment outside the EAO). Nicole Del Raye provided support in final formatting of the document. Their assistance is appreciated.  \u000CTable 3: Selected Examples of Approaches to Addressing Reclamation Issues Issue Mine Project Approach to addressing the issue (selected examples only) Reclamation Ruby Creek \u2022 Remove project infrastructure and rehabilitate affected areas so that they Objectives Molybdenum are able to be used for selected land uses. Land uses contemplated for the Project plan include primarily wildlife habitat. \u2022 Achieve post-closure site conditions that are both physically and chemically stable. \u2022 Protect the public in areas affected by project activities or installations, by reducing the hazards to levels equal to or below those naturally existing within the surrounding environment. \u2022 Achieve passive maintenance (post-closure) within 5 years from the completion of the project operating phase. \u2022 Goal of revegetation and rehabilitation of the project footprint is 80%. Red Chris Copper-Gold Project  \u2022 Primary objective of the reclamation plan will be to return where practical all areas disturbed by mining operations to their pre-mining land use and capability. This implicitly includes: \u2022 The long-term preservation of water quality within and downstream of de-commissioned operations; \u2022 The long-term stability of engineered structures, including the waste rock dumps, open pit and tailings impoundment; \u2022 The removal and proper disposal of all access roads, structures and equipment that will not be required after the end of the mine life; \u2022 The long-term stabilization of all exposed erodible materials; \u2022 The natural integration of disturbed areas into the surrounding landscape, and the restoration of a natural appearance to the disturbed areas after mining ceases, to the best practical extent; and \u2022 The establishment of a self-sustaining cover of vegetation that is consistent with existing.  Swamp Point Aggregate Project  \u2022 The overall concept for reclamation and end land use objectives is to create post-mine ecosystems with similar ecological values and land capabilities as existed pre-mine. \u2022 Identification of post-mine ecological units that are based on post-mine landforms, aspects, substrates and moisture regimes; available soil quantities and quality; and use of locally native and non-selected plant materials to the extent practicable. Expected plant succession at the site and wildlife habitat values are integral to the planning of post-mine features and to plant materials selection.  Brule Coal Project  \u2022 The primary focus of the reclamation program is to foster return to appropriate and functional ecosystems, supported by soil salvage and replacement strategies that ensure this is possible. \u2022 Reclamation will be conducted with the goal of establishing equivalent post-mine capability for a variety of end land uses. If this objective is achieved, ecosystem variety and vegetation dynamics will ensure that the post-closure landscape is capable of productively supporting a range of simultaneous end land uses (e.g., an area with potential for commercial forestry will also provide valuable wildlife habitat).  \u000CTable 3 (continued): Selected Examples of Approaches to Addressing Reclamation Issues Issue Mine Project Approach to addressing the issue (selected examples only) Water Red Chris \u2022 Mitigate potential water quality impacts by treating contaminated water Quality &amp; Copper Gold from both the North Dump and open pit in the post-closure period (after ML / ARD Project the mined out pit has flooded) as required to meet discharge criteria. \u2022 Implement water treatment, if necessary, to ensure that the effluent discharged from the tailings impoundment is of sufficient quality to protect aquatic life in the receiving drainage systems both during the mine\u2019s operational life and into post-closure. Wolverine \u2022 Design mitigations and monitoring controls to reduce ML/ARD from Coal Project coarse coal reject into potential waterfowl habitat. \u2022 Design mitigations and monitoring controls to reduce input of ML/ARD into Wolverine River and Perry Creek from dumps, coarse coal reject, and tailings ponds. (specific actions were provided for both bullets above) Galore Creek \u2022 Maintain intensive receiving environment monitoring programs to ensure Copper Gold water quality and wildlife resources are protected for future generations. Project \u2022 Progressive reclamation where possible to control sedimentation. \u2022 All waste rock will be placed within the catchment area of the impoundment. Potentially acid generating (PAG) rock will be placed for permanent underwater disposal. Not-PAG rock will be placed in upland dumps. Orca Sand \u2022 Turbidity levels will be monitored during pile placement and visual and Gravel inspections for oil sheens on water will be undertaken during marine Project construction. Terrestrial Wolverine \u2022 Monitoring of the reclaimed landscape will be conducted both Ecosystems, Coal Project immediately after reclamation treatments, to assess success in reVegetation, establishing vegetation on the reclaimed landscape, and over time to assess Soils the effectiveness of the reclamation program in achieving objectives. Galore Creek \u2022 Avoid/minimize disturbance in red and blue-listed ecological Copper Gold communities tracked by the BC Conservation Data Centre Project \u2022 Ensure rapid revegetation of exposed soil (e.g., road cuts, recently disturbed areas) to minimize establishment of invasive plant species. Orca Sand \u2022 No soils will be removed from site. All soils will be stripped by type \u2013 and Gravel topsoils separately from subsoils, and either used immediately for Project reclamation or stored for final reclamation. Wildlife and Eagle Rock \u2022 Old growth clearing to be monitored for significant Marbled Murrelet Wildlife Quarry presence. If found, commit to habitat compensation and to enter into Habitat Project discussions to develop an appropriate habitat compensation strategy. Brule Coal \u2022 Reclamation planning has and will continue to consider wildlife habitat Project use both during operations and post-closure. Interim re-vegetation planning for erosion control will consider facility locations and minimizing or avoiding the use of vegetation species that will be attractants to bears and other wildlife. Particular attention will be paid to the selection of vegetation species for roadside reclamation.  "@en
<https://open.library.ubc.ca/cIRcle/collections/59367/items/1.0042537>