Dr. Oliver Fringer
Oceanographer and expert in modelling coastal systems, associate professor in the
Dept.of Civil and Environmental Engineering at Stanford University.
Dr. Oliver Fringer concludes that the Stantec Receiving Water Studies, on which much of the NPNS EA is founded, are unreliable and fundamentally inaccurate. The modelling exercise undertaken was not appropriate for the receiving environment and is not an accurate representation of effluent and sediment interaction with that environment.
Dr. Alain Murphy - Marine Geologist
“... the geological and geophysical data illustrate that there are too many risks to consider putting a pipeline along the proposed route. Contrary to demonstrating that this is a good candidate for the pipeline routing, the various data highlight multiple mechanisms by which damage could be sustained to the pipeline
Dr. Lynn Cameron - Organic Chemist
"The proposed treatment facility is not appropriate because it will not sufficiently remove AOX which is composed of toxic organic chlorides including PCBs and chlorinated dioxins and furans. Nor does the facility remove excess nitrogen and phosphorous which can lead to eutrophication and ultimately harmful algal blooms (HABs).”
Dr. Keith Laidig – Organic Chemist
“The Veolia expected performance of the proposed ETF are overly optimistic given the results of the lab study presented in the Focus Report … the authors incorrectly imply that organic halides from bleach Kraft pulping processes are short-lived contaminants in the environment.”
Colton Cameron, BSc Eng & Fisherman
"In previous comments, submitted in response to Northern Pulp’s Environmental Assessment, I highlighted concerns of pipe failure due to the presence of ice along the proposed pipe route. The issues raised in that submission have not been addressed by Northern Pulp in the Focus Report. The risk of damage to the marine pipe by ice is critical to determine the viability of the proposed project. ..."
Dr. Elaine MacDonald - Environmental Engineer
"The air quality analysis included with the Focus Report should be considered unreliable and incomplete. The input data is not site-specific and the chosen model is not appropriate for a coastal location with complex terrain.”
Caribou Harbour Authority
The Caribou Harbour Authority operates the busiest fishing port in Northern Nova Scotia. It is the site of Northern Pulp Nova Scotia’s (NPNS) proposed marine effluent pipeline and effluent outfall. The Harbour Authority submission addresses ten critical points of concern including errors of fact relating to fisheries and presence of fish, no leak detection for marine portions of effluent pipe, risk of siltation during construction causing significant harm to marine life and to current users of the harbour, navigation issues and more.
Peter Dodge - Mechanical Engineer
Peter Dodge questions "whether this bio sludge qualifies as a fuel and thus qualifies as exempt from more stringent controls when considered as incineration of a waste product,” and also points to air quality issues relating to “existing inconsistent operation inherent in burning solid fuels” and that the “[a]ddition of bio sludge into the Power Boiler will further complicate the operation, as fuel input and mixing would not be stable.”
Ryan MacDonald - Fisherman & Millwright
Ryan MacDonald provides evidence that the proposed outfall falls inside a marine refuge, set up to protect juvenile lobster and that this is contrary to the prohibitions for the marine refuge that state, “ No other human activities that take place in this area are incompatible with the conservation of the ecological components of interest.” He also highlights risks of shellfish closure zones, the potential impacts of over 4 tonnes of Total Suspended Solids a day in an area that quickly changes from 20m depth to shallow waters, and in-mill issues.
Fishing Industry Submission
Jamie Simpson on behalf of Gulf Nova Scotia Fleet Planning Board, PEI Fishermen’s Association,
Maritime Fishermen’s Union
“It is clear that NPNS has failed to provide a complete response to the terms of reference for the required Focus report, and furthermore, the information provided by NPNS, incomplete as it is, raises concern for significant and unacceptable adverse impact risks for the Northumberland Strait marine ecosystem, local communities, and the fishing industry sector. The health of the marine environment and the region’s seafood sector hangs in the balance.
If you permit NPNS’s project to proceed, you are putting the Atlantic Canada seafood products, and the fishing industry that provides these products , at risk, as well as the health of the Northumberland Strait marine environment.”
Dr. Andrea Battison
Veterinary clinical pathologist, with extensive experience in the study of animal disease and interpretation of laboratory results and associated quality assurance data. Ph.D. is in the field of lobster health assessment.
“The exclusion of many metals from the list of COPC [Chemicals of Public Concern] and minimal Information on bioaccumulation is concerning as metals are known to be toxic to American Lobster.” …
Dr. Laura Braden
Director of Molecular Genetics and Biotechnology at AquaBounty Canada, and Adjunct Professor in the Department of Veterinary Medicine at the Atlantic Veterinary College.
“The negative physiological effect of BKPME [Bleached Kraft Pulp Mill Effluent] has been well described on fishes, including depressed immunity, altered reproduction and decreased overall resilience…. [furthermore] there is no description or characterization of the potential for components of the predicted BKPME for bioaccumulation, despite the large body of evidence for bioaccumulation of several toxic components such as chlorinated organic compounds and woodextractives. … There is limited-to-no information regarding the true chemical characteristics of the proposed effluent.”
Dr. Arnault Le Bris, Ph.D.
Research Scientist in Coastal and Fisheries Ecology with the Fisheries and Marine Institute,
“My major concern is that the one-month simulation period is not sufficient to evaluate the cumulative impacts of effluent waters released continuously for several years, possibly decades.… the focus report does not adequately address the risks of bioaccumulation of toxins in the marine environment. … The short duration [fish habitat]survey…was unable to capture seasonal variations in fish communities and fish habitat; therefore, it has limited value as a baseline survey. … “In my professional opinion, given the information presented in the focus report and associated documents, it is impossible to conclude that the proposed work won’t lead to harmful alteration, disruption, or destruction of fish habitat.”
NEXUS Coastal Resource Management Ltd
“Consensus within the scientific and technical community is that COPC [Chemicals of Public Concern] disposal, particularly those identified as endocrine disruptors and persistent … pollutants in marine environments is of mounting concern… and that conventional treatment options (including activated sludge processes as proposed in this ETF) are considered to be insufficient to address concerns regarding commercial fisheries. This is particularly in light of mounting concerns over the need for more stringent attention to cumulative effects and consideration of increasing stress indicators of ocean health. [refs. omitted]…
The potential effect of TSS is dependent on the type of raw material introduced to the natural environment and the nature of the receiving environment. Therefore, comparisons of models using effluent from mills in other regions is irrelevant and can lead to inaccurate conclusions. ”
Barb Harris - River John, NS
Barb Harris examines the acknowledged problem of COD exceedences from black liquour spills at NPNS, and the potential these could compromise efficiency of the new ETF, leading to release of untreated or undertreated effluent into the Northumberland Strait. She points to similar potential risks from present disposal methods of waste dangerous goods at NPNS.