3 TOR response points
you can use

The purpose of the Terms of Reference (TOR) is to give direction to Northern Pulp about what information must be included in their Environmental Assessment Report.  

This stage is just about the TOR and not about whether Northern Pulp should be allowed to build their new ETF.  Any comments to NS Environment & Climate Change (NSECC) should just be about the TOR itself.

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FONS is working hard with our lawyers, Ecojustice, to provide NSECC a thorough response to the draft Terms of Reference. 

In the meantime, here are a few points you may like to use in your response:

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1. I appreciate that NSECC’s Draft Terms of Reference for Northern Pulp's proposed project are detailed and broad, and require accountability from Northern Pulp. I support NSECC’s adherence to the standards set out in Nova Scotia Environmental Assessment regulations.  Please do not bow to pressure from Northern Pulp to weaken the Draft TOR.  
    

2. I support NSECC’s explanation (Section 10, p. 29)  on why setting limits on contaminants before studies and analysis is not appropriate.  Hard targets cannot be determined without fully evaluating the specific receiving environment.
    

3. I would like the TOR to require that Northern Pulp release their Receiving Water Study and discharge point to the public as soon as those are determined, and not wait to release them until a completed Environment Assessment Report is submitted. 

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Links: 

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Draft Terms of Reference

Northern Pulp's Registration Document

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If you would like to use your own comments, FONS has put together a few tips on how to respond to the Draft Terms of Reference.

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