A sampling of comments to Nova Scotia Environment about Northern Pulp's Environmental Assessment for their proposed effluent treatment facility.
Chris Miller, Ph.D., Executive Director
Canadian Parks and Wilderness Society, NS Chapters
Despite the lack of evidence presented, and despite only carrying out a single day of fieldwork where no real data was generated, the Proponent reaches a rather firm conclusion that the proposed undertaking will not impact wetlands. The report states the following:
“With the proper implementation of proposed mitigation measures, impacts to wetlands as a result of construction of the project are not anticipated to be significant” (Pg.240)
I simply cannot see how anyone could reach such a conclusion about wetlands from the paltry amount of data provided. It is not okay for a proponent to seek environmental approvals now, without having completed the necessary work, under the promise that it will be done at a later date, after approvals are already received. That’s not how environmental assessments should work.
Colten Cameron – P.Eng and Commercial Fisherman
One of the causes for failures of HDPE pipes is fatigue which is the result of pipes being subjected to cyclic loading, such as internal pressure, weight loads or external loadings on buried pipes, which generates stress in different directions: circumferential, longitudinal and radial.” (P.600,Djebi et al.,2014). To accurately determine these site-specific loads, various data is required including bottom type/depths, potential ice scours, and the site observations of ice conditions. It should be noted that none of these are present in Northern Pulp’s submission.
David Scanlan - Pictou County, NS
Figure 8.12-6 is also not accurate. The map does not show the herring nursery which is in the area of the outfall. Also, there is herring fishing all around Pictou Island and not just as indicated. We also fish for herring in the area of the proposed outfall location. Herring is a fixed gear fishery. We use anchors on each end of our herring nets. The pipe and proposed no anchor zone will significantly interfere with our herring fishery. It is not possible for us to simply go somewhere else to fish if the fish are located in the area of the outfall or the no anchor zone and not anywhere else. The herring pack consists of a large group of boats all fishing for herring at once - possibly 200 boats in the same close area at one time. The pack is so large that sometimes the PEI ferry steers out of its normal route to avoid us.
Janice Cruikshanks - Caribou Harbour, NS
I was aware of 2 sunken ships in Caribou Harbour so did a scan of some public records (Eastern Chronicle, Pictou Advocate, Maritime Museum of the Atlantic, The News) and found not 2 but 22 reports of strandings and wrecks – a listing is attached. There were also 3 ferry crossing points from Caribou Island to “the mainland” years ago – one at the West end , one mid-island and one at the East end I don’t know if there is evidence of old wharf pilings at the East end of the island but there are at the other 2 locations. This information relates to Section 10.2.8 Discovery of a Heritage Resource. The Special Places Protection Act , Historical Sites & Monuments Board of Canada and the Heritage Trust of Nova Scotia also need to be considered for ensuring that the Marine Heritage of Caribou Harbour and area is not sacrificed.
[FONS Note: P 460 of Northern Pulps documents sets out10 known ship wrecks in the vicinity of the marine PFA/LAA.]
Linda Irving, MPA - Tatamagouche, NS
In the instant NP Proposal, data is derived from models created and operated in controlled environments. In the natural world, the number of variables that affect the validity of the data are either too numerous to list, or are simply unknown. Statistical confidence intervals of conclusions in this proposal are not stated, nor are any statistical analyses mentioned. All scientific and technical data must withstand statistical scrutiny. This is meant to address the probability that the data is replicable and applicable in the natural environment or larger population. There is no mention in the NP Proposal of how the models utilized by Stantec were validated, yet numerous assumptions/conclusions regarding the performance parameters of the proposed project are presented.
Jill Graham Scanlan - Pictou County
In my review of Northern Pulp’s proposed Replacement Effluent Treatment Facility (ETF) Project, I identified many errors, misrepresentations, and concerns. These are as follows:
1. Definitions: Commencing at Page xxiii, there are a number of words that are defined for the purposes of the proposal. Not all of the definitions used are the same as the definitions of the same terms used in relevant legislation, including the following definitions (emphasis are mine):
(a) Contaminant is defined in the Environment Act as: “contaminant” means, unless otherwise defined in the regulations, a substance that causes or may cause an adverse effect;
Contaminant is defined in the ETF proposal as: “A biological, chemical, physical or radiological substance that becomes harmful for humans or living organisms, when accidentally or deliberately introduced to air, water, soil or food.”
Matt Dort - Pictou County
The new proposal also shows a plan to burn contaminated sludge in power boiler which raises new threats to air quality. The waste sludge contains toxins which would be released through the stacks of the mill’s power boiler. The proposal is to "dewater the sludge prior to mixing it with bark and other woodwaste for combustion in the mill's power boiler." This is the same power boiler that is currently and repeatedly failing stack emissions tests.
Ecology Action Centre – Halifax, NS
Despite its impressive volume, NPNS’s registration documents is very poor and fails to provide necessary information about key elements of their plan, including and importantly – the content of the substances they wish to pump in large volumes into the Northumberland Strait and the potential impacts that it undoubtedly will have on marine life and air quality. The registration document seems designed to obfuscate essential details, downplay them or intentionally omit them altogether.
Emelyne Marshall, PhC - a pharmacist view
The people of Pictou County are chronically ill and the incidence of COPD, asthma and environmental allergies is astounding.
Pharmacists are widely recognized as the most accessible health care professionals and as such, our role extends far beyond counting pills. On a daily basis, I assess, make recommendations, prescribe, counsel and refer these patients that present to the pharmacy to other primary care providers. Common complaints range from “My sinuses are acting up” to “I need another puffer; my chest feels tight, I can’t breathe”. These complaints are often followed by “because the mill is blowing this way today”. This is not exclusive to any one pharmacy in Pictou County. Typically, when talking to patients about COPD, asthma and environmental allergies, I would counsel on avoidance of triggers. This has become a laughable counseling point because my patients cannot avoid the community they live in or the jobs that they hold.
Hannah Fleury, Nine-Year-Old from Caribou, NS
In school we talk about not littering, reduce, reuse and recycle. We learn about pollution and what we can do to help the Earth, but we are not allowed to talk about Northern Pulp even though some days when the wind is blowing the smog toward our school we have to play inside because the air hurts to breathe and it smells worse than dog farts. If you allow them to build their new system it will be burning sludge on top of what they burn now, it will be worse.
Charlie McGeoghegan, Belfast, PEI
President of Lobster Fishers of PEI Marketing Board
This very location that Northern Pulp has picked for the outfall pipe, is a “Marine Refuge” officially designated by DFO, meaning it is prime fishing grounds and is protected, it is part of the MPA process. How could it be used as an industrial toxic dump zone? Seriously?? 90,000,000 litres a day of unknown effluent with 4 tonnes of solids mixed in ?? Dumped on a Marine Refuge!
100% of the risk is on us (commercial fishers) right now, and that is NOT an option!
Halifax, NS and Cottage Owner on Moody’s Cove
The double-barreled punch of a high nutrient load along with higher temperature will be absolutely devastating for the Strait. Boat Harbour currently buffers these stressors by lowering the temperature of the pollutants and removing a great deal of the solid biomass. With current ocean research demonstrating that our waters cannot adjust, cannot adapt and are indeed suffering much like our forests are with the effects of climate change, how can we justify adding up to 90 million litres of effluent per day into an already-stressed ecosystem?
Harbour Authority of Caribou
Northern Pulp’s current proposal (section 22.214.171.124) confirms that there has been no testing completed with respect to the water composition of Caribou Harbour. Instead Pictou Harbour was used as a proxy for Caribou Harbour with respect to water quality. There is no explanation as to why water quality data for Caribou Harbour was “unavailable”. The Authority views such an assumption on water composition as entirely inadequate. There are major distinctions between the two harbours which makes such an assumption tenuous at best.
Dave Gunning - Pictou County
Many first nations people and non-natives have had this pollution dumped on them for over 50 years. But our entire, and one and only Mi’Kmaq community have been victims of environmental racism from the beginning and throughout the entire history of this mill. It must be stopped and they must be protected and respected in a real and meaningful way moving forward. Moving the pollution from their backyard to their front yard and putting their fishing fleet at risk would not be the way to do this!
Barb Harris - River John, NS
I have spent the last month immersed in 1700 pages of documentation which the public was given only 30 days to read, understand and respond to. I believe that this was not an adequate process of public consultation, especially as no Open Houses were conducted on the proposal including the new route, new outfall location, and many differences in technology, including a missing oxygen delignification system
Peter Ryan - Caribou, NS
....NNPNS has advanced, from Australia, the Toxikos 2006 study ‘Comment on Bell Bay effluent and potential impact on nearby seal colonies’ for a future Human Health Evaluation. NPNS regularly states the mill effluent in the Toxikos report is comparable to that of its own projected operation, and therefore the risks to human health are negligible...
.....The conclusions from the Toxidos (2006) study and the Dr. Andrew W. Wadsley’s audit are so contradictory that a thorough Human Health Risk Assessment is called for prior to releasing NPNS’ effluent into the Northumberland Strait as its impact on sensitive aquatic organism, marine mammals, birds, fish and humans may be significant.
Jeff Hilchey, P.Eng & Krista Hilchey, B.Sc., M.Sc
The EA relies heavily on the 1992 Pulp and Paper Effluent Regulations (PPER) which are part of the Fisheries Act. The report states that “The effluent is anticipated to meet compliance with federal PPER.” It should be noted that the EA provides no evidence to support this statement. No calculations of maximum total suspended solids (TSS) or biochemical oxygen demand (BOD) (which is how the PPER regulates effluent) are provided.
Tourism Industry of Nova Scotia
According to the latest tourism statistics, tourism revenue in the Northumberland Shore Region is 7.8% of the total tourism revenues translating to $210.6 Million1. The NP EA states 8.3 % and $215 Million. Pictou County estimates are 3% or $81 Million.
However, the length of stay in the Town of Pictou has declined from 2010, an average of 3.3 days to 2017 at 2.5 days. Tourism Operators explain the decline in visitor stay is a direct result of the various factors emanating from the effect of the Northern Pulp Mill.
The reference to Tourism, on page 438, does a disservice to the importance that tourism plays in the region and the significant economic damage from the environmental risks proposed by Northern Pulp’s plan.